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CREEVYQUINSOLAR FARMPLANNING & ENVIRONMENTAL REPORT GAELECTRIC RENEWABLE ENERGY DEVELOPMENTS LTD

Creevyquin Solar Farm Contents

Planning and Environmental Report

Gaelectric Renewable Energy Developments Ltd i January 2017 November 2016

CREEVYQUIN PLANNING APPLICATION

CONTENTS

1. INTRODUCTION 1.1. Overview 1-1 1.2. Structure of Planning and Environment Report 1-1 1.3. The Applicant 1-2 1.4. Pre-Planning Engagement 1-2 1.5. Environmental Impact Assessment Screening 1-2 1.6. Public Consultation 1-3

2. PLANNING POLICY CONTEXT

2.1. Introduction 2-1 2.2. International Policy 2-1 2.3. National Policy 2-1 2.4. Regional Policy 2-4 2.5. Local Policy 2-5 2.6. Conclusion 2-8

3. RELEVANT PLANNING HISTORY

3.1. Local Planning History 3-1 3.2. Overview – Solar Planning Applications in Ireland 3-1 3.3. Waterford County Council Planning Reference 16/126 3-2 3.4. Wicklow County Council Planning Reference: 16/176 3-6 3.5. Cork County Council Planning Reference: 15/5424 3-9 3.6. Wexford County Council Planning Reference: 20140392 3-12 3.7. Cork County Council Planning Reference: 14/06644 3-15 3.8. Conclusion 3-16

4. SITE LOCATION AND PROJECT DESCRIPTION

4.1. Overview 4-1 4.2. Site Location 4-1 4.3. Site Criteria Selection 4-2 4.4. Surrounding Area 4-2 4.5. Site Infrastructure 4-3

4.5.1. Solar Panels and Mounting Frames 4-3 4.5.2. Inverter and Transformer Stations 4-4 4.5.3. Substation Building 4-5 4.5.4. Fencing and Security 4-5 4.5.5. Weather Station 4-6 4.5.6. Spare Parts Container 4-6 4.5.7. Access and Site Tracks 4-6 4.5.8. Temporary Construction Compound 4-7 4.5.9. Grid Connection 4-8

4.6. Design Approach 4-8 4.7. Operation and Maintenance 4-9 4.8. Construction and Decommissioning 4-9 4.9. Benefits 4-9

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ii Gaelectric Renewable Energy Developments Ltd January 2017

4.9.1. Overview 4-9 4.9.2. Economic Benefits 4-10 4.9.3. Environmental Benefits 4-10 4.9.4. Social Benefits 4-11

5. ECOLOGICAL IMPACT ASSESSMENT & APPROPRIATE ASSESSMENT SCREENING

5.1. Overview 5-1 5.2. Ecological Impact Assessment 5-1

5.2.1. Surveys Conducted 5-1 5.2.2. Impact Assessment 5-1 5.2.3. Mitigation 5-3

5.3. Appropriate Assessment Screening 5-4 6. LANDSCAPE AND VISUAL IMPACT ASSESSMENT AND GLINT AND GLARE

6.1. Overview 6-1 6.2. Landscape and Visual Impact Assessment 6-1

6.2.1. Pre-Application Consultation 6-1 6.2.2. Planning Precedent 6-1 6.2.2.1. Wicklow County Council Planning Reference: 16/176 6-1

6.2.2.2. Wexford County Council Planning Reference: 20140392 6-1

6.2.2.3. Cork County Council Planning Reference: 14/06644 6-2

6.2.3. Methodology 6-2 6.2.4. Zone of Theoretical Visibility 6-3 6.2.5. Landscape Impact 6-3 6.2.6. Visual Impact 6-4 6.2.7. Mitigation 6-4 6.2.8. Conclusion 6-5

6.3. Glint and Glare 6-5 6.3.1. Introduction 6-5 6.3.2. Planning Precedent 6-5 6.3.2.1. Wicklow County Council Planning Reference: 16/176 6-5 6.3.2.2. Cork County Council Planning Reference: 15/5424 6-5 6.3.2.3. Wexford County Council Planning Reference: 20140392 6-6 6.3.2.4. Cork County Council Planning Reference: 14/06644 6-6 6.3.3. Methodology 6-6 6.3.4. Summary of Results 6-6 6.3.5. Conclusion 6-7

7. ARCHAEOLOGY, ARCHITECTURAL & CULTURAL HERITAGE ASSESSMENT

7.1. Overview 7-1 7.2. Methodology 7-1 7.3. Baseline Heritage and Archaeology 7-1 7.4. Assessment of Impacts 7-1

7.4.1. Direct Impacts 7-1 7.4.2. Indirect Impacts 7-2

7.5. Mitigation Measures 7-2 7.6. Compliance with NMS Guidance 7-3 7.7. Conclusion 7-3

Creevyquin Solar Farm Contents


Gaelectric Renewable Energy Developments Ltd iii January 2017 November 2016

8. TRAFFIC AND TRANSPORT ASSESSMENT 8.1. Overview 8-1

8.1.1. Pre Planning Advice 8-1 8.2. Traffic and Transport 8-1

8.2.1. Proposed Site Access 8-1 8.2.2. Haul Routes to Site for Construction Traffic 8-2 8.2.3. Construction Traffic Management 8-2 8.2.4. Construction Parking 8-2 8.2.5. Operational Period 8-3 8.2.6. Decommissioning Period 8-3 8.2.7. Mitigation 8-3

8.3. Conclusion 8-4 9. HYDROLOGY, GEOLOGY AND FLOOD RISK ASSESSMENT

9.1. Overview 9-1 9.2. Baseline 9-1 9.3. Assessment of Impacts 9-3

9.3.1. Construction Phase 9-3 9.3.2. Operational Phase 9-4 9.3.3. Decommissioning Phase 9-4

9.4. Flood Risk Assessment 9-4 9.4.1. Phase 1 Flood Risk Identification 9-4 9.4.2. Conclusions 9-4

9.5. Drainage Impact Assessment 9-5 9.5.1. Proposed Drainage Strategy 9-5

9.6. Mitigation 9-6 9.6.1. Geology, Hydrology and Hydrogeology 9-6

10. NOISE

10.1. Overview 10-1 10.2. Construction Noise 10-1 10.3. Operation Noise 10-1

10.3.1. Planning Precedent 10-1 10.3.2. Operational Noise Impact Assessment 10-2

11. SUGGESTED CONDITIONS 11.1. Introduction 11-1 11.2. Conditions 11-1

11.2.1. Site Layout and Design 11-1 11.2.2. Construction 11-1 11.2.3. Decommissioning 11-1

12. CONCLUSIONS

12.1. Introduction 12-1 12.2. Concluding Comments 12-1

Contents Creevyquin Solar Farm


iv Gaelectric Renewable Energy Developments Ltd January 2017

LIST OF APPENDICES Appendix A: Public Consultation Information

Appendix B: Noise Impact Assessment

Appendix C: Ecological Impact Assessment

Appendix D: Appropriate Assessment Screening Report

Appendix E: Outline Construction Environmental Management Plan

Appendix F: Landscape and Visual Impact Assessment

Appendix G: Ecological & Landscape Mitigation Plan

Appendix H: Glint and Glare Assessment

Appendix I: Archaeology, Architectural Heritage & Cultural Heritage Impact Assessment

Appendix J: Construction Traffic Management Plan

Appendix K: Hydrology, Geology and Flood Risk Assessment

Appendix L: Tree Survey Report

Creevyquin Solar Farm Section 1

Planning and Environmental Report Introduction

Gaelectric Renewable Energy Developments Ltd Page 1-1 January 2017

1.0 INTRODUCTION

1.1 OVERVIEW

Gaelectric Renewable Energy Developments Ltd (“the Applicant”) is seeking to apply for planning

permission to develop a solar photovoltaic (“solar PV”) energy generation project on lands at

Creevyquin, Roscommon, Co Roscommon (“the Application Site”).

The development will consist of a 10 year planning permission for the development of a solar

photovoltaic (“PV”) energy development to include: a single storey electrical substation building,

electrical inverter and transformer stations, solar PV panels mounted on metal frames, new access

tracks, underground cabling, perimeter fencing with infrared CCTV and access gates, temporary

construction compound, spare parts container, weather station, a new access point and all ancillary

infrastructure and associated works within a total site area of up to 34 acres.

The Development will be connected to the local road network via a new access point on the southern

boundary of the Application Site.

This Planning and Environmental Report has been prepared by the Applicant to accompany the

submission of a planning application for the Creevyquin Solar Farm to Roscommon County Council. The

purpose of the document is to provide additional information regarding the Development and any

potential effects on the receiving environment.

1.2 STRUCTURE OF THE PLANNING AND ENVIRONMENTAL REPORT

This Planning and Environmental Report is structured as follows:

- Section 1: Introduction;

- Section 2: Planning Policy Context;

- Section 3: Relevant Planning History;

- Section 4: Site Location and Project Description

- Section 5: Ecological Impact Assessment & Appropriate Assessment Screening;

- Section 6: Landscape and Visual Impact Assessment and Glint and Glare Analysis;

- Section 7: Archaeological, Architectural Heritage & Cultural Heritage Assessment;

- Section 8: Traffic and Transport;

- Section 9: Hydrology, Geology and Flood Risk Assessment;

- Section 10: Noise Impact Assessment;

- Section 11: Suggested Conditions; and

- Section 12: Conclusion.

The Planning and Environment Report also contains the following appendices:

- Appendix A: Public Consultation Information;

- Appendix B: Noise Impact Assessment;

- Appendix C: Ecological Appraisal;

Section 1 Creevyquin Solar Farm

Introduction Planning and Environmental Report

Page 1-2 Gaelectric Renewable Energy Developments Ltd January 2017

- Appendix D: Appropriate Assessment Screening Report;

- Appendix E: Outline Construction Environmental Management Plan;

- Appendix F: Landscape and Visual Impact Assessment;

- Appendix G: Ecological Landscape Mitigation Plan;

- Appendix H: Glint and Glare Assessment;

- Appendix I: Archaeology, Architectural Heritage & Cultural Heritage Assessment;

- Appendix J: Construction Traffic Management Plan;

- Appendix K: Hydrology, Geology and Flood Risk Assessment; and

- Appendix L: Tree Survey Report.

1.3 THE APPLICANT

This planning application is submitted by Gaelectric Renewable Energy Developments Ltd, a company

within the wider Gaelectric Group (“Gaelectric”). Gaelectric is an independent wind and energy storage

development company operating within Northern Ireland, the Republic of Ireland and North America.

Founded in 2004, Gaelectric has become a leading independent developer and operator of renewable

energy projects in wind, bioenergy and solar on the island of Ireland and in Great Britain. The company

is currently working to develop a significant portfolio of solar projects throughout the island of Ireland.

Gaelectric has compiled this Planning and Environment Report and carried out, in conjunction with

other specialist consultants, the supporting environmental reports for the proposed Development.

1.4. PRE-PLANNING ENGAGEMENT

Gaelectric attended a pre-planning application consultation meeting with Roscommon County Council

on 3rd August 2016 to introduce the project and scope the requirements for the planning application.

The consultation undertaken has assisted in the design of the proposed Development and the

preparation of the planning application.

Planners from Roscommon County Council requested that the 2 storey properties with primary views

of the Application Site be consulted. This consultation was carried out and the property listed as

Receptor 9 has submitted a letter of support which accompanies this planning application.

In total 3 letters of support have been submitted with this application and they are provided in

Appendix A.7 Letters of Support.

1.5 ENVIRONMENTAL IMPACT ASSESSMENT SCREENING

Schedule 5 of the Planning and Development Regulations (2001) (as amended), sets out Annex I and

Annex II projects which mandatorily require an Environmental Impact Statement (“EIS”).

Part 1, Schedule 5 outlines classes of development that require EIS and Part 2, Schedule 5 outlines

classes of developments that require EIS but are subject to thresholds.

The proposed Development does not fall within Parts 1 and 2 of Schedule 5 of the Planning and

Development Regulations (2001) (as amended), and therefore does not trigger a mandatory

Environmental Impact Assessment (“EIA”).




The conclusions drawn by An Bord Pleanala (Reference no’s PL26.246527, PL04.244539, PL26.244351

and PL04.245862) are noted whereby it is considered that a proposed solar farm development is not

included in the project description of Part 1 and Part 2, Schedule 5 projects and whilst that there are

some projects under Paragraph 3 ‘Energy Projects’ which relate to energy production, it was also

contended that none of these projects would be applicable to a solar farm as proposed.

In accordance with the ‘EIA Guidance for Consent Authorities regarding Sub-threshold Development’1

(2003), the following is stated “there is a requirement to carry EIA where competent/consent authority

considers that a development would be likely to have significant effects on the environment”.

Article 92 of the Planning and Development Regulations (2001) (as amended) defines sub-threshold

development, i.e. “development of a type set out in Schedule 5 which does not exceed a quantity, area

or other limit specified in that Schedule in respect of the relevant class of development”.

Article 103 of the Planning and Development Regulations (2001) (as amended) indicates that where a

Planning Authority is of the view that a sub threshold development would be likely to have significant

effects on the environment they can require the applicant to submit an EIS. The criteria for determining

whether a sub-threshold development is likely to have significant effects on the environment and

therefore would require an EIS is outlined in Schedule 7 of the Planning and Development Regulations

(2001) (as amended). These criteria includes (i) characteristics of the proposed development, (ii)

location of the proposed development, and (iii) characteristics of potential impacts.

As it is determined above that a solar farm development is not a development set out in Schedule 5, it

is therefore considered that the subject development is not a ‘sub-threshold development’ for the

purpose of EIS. Again, the conclusions drawn by An Bord Pleanala (Planning Reference PL27.246527)

are noted and indicate that a solar farm development would not require a mandatory EIS nor would

classed ‘sub-threshold development’.

In the An Bord Pleanala file PL27.246527, the Inspector’s Report notes:

“As I have considered above that the solar panel development is not a development set out in

Schedule 5 then I would not consider that the subject development is a ‘sub-threshold

development’ for the purpose of EIS”.

Notwithstanding the above, this Planning and Environment Report and supporting environmental

reports address a number of potential environmental issues including; Ecological Impact Assessment,

Landscape and Visual Impact Assessment, Glint and Glare Analysis, Archaeology Architectural Heritage

& Cultural Heritage Assessment, Traffic and Transport Assessment, Noise and Hydrology, Geology and

Flood Risk Assessment.

1.6 PUBLIC CONSULTATION

Whilst community consultation is not a mandatory planning requirement, the Applicant voluntarily chose

to undertake a community consultation as they believe that this represents best practice and they value

the opinions of the local community.

The aim and objective of the community consultation has been to inform the local community of the

proposed Development, explain to them in simple terms the proposed Development and its likely

effects, articulate the wider socio-economic benefits that the project will deliver and seek their feedback

to enable their views to be known and help refine the proposals prior to the submission of the planning

application.

1 Department of the Environment, Heritage and Local Government (2003) ‘EIA Guidance for Consent Authorities regarding Sub-threshold Development’. Available at http://www.housing.gov.ie/sites/default/files/migrated-files/en/Publications/Environment/Miscellaneous/FileDownLoad,1804,en.pdf [accessed 05/09/2016].


Introduction Planning and Environmental Report


Engaging communities is an essential part of an effective and inclusive planning application process.

The pre-application consultation with the community is intended to add value at the start of the project

development process by improving the quality of the proposal and allowing applicants the opportunity

to amend their emerging proposals to accommodate community and stakeholder opinion.

Where applicants engage in meaningful pre-application consultation, local communities can be better

informed about development proposals and have an opportunity to contribute their views before a

formal planning application is submitted. In so doing, it is hoped this will:

- Improve the quality of planning applications received;

- Mitigate negative impacts where possible;

- Address community issues or misunderstandings; and

- Provide for smoother and more effective decision making.

A community consultation event was held on 30th November 2016 at The Crofton Suite, Abbey Hotel,

Galway Road, Roscommon, Co Roscommon, F42 F992 between 3.30pm and 8.00pm. Appendix A

provides a compilation of the community consultation information associated with the proposed

Development.

Notice of the community consultation event was published in the Roscommon People on 18th November

2016 and a copy of this notice is included as Appendix A.1.

Residents within a defined zone of the Application Site were also identified and informed directly about

the community consultation event. A map detailing the zone is included as Appendix A.4. The

notification letter delivered to residents and indicative site location map is included as Appendix A.3.

The community consultation event provided information about Gaelectric and the proposed

Development, and included information on potential impacts on ecology, traffic and transport,

hydrology, archaeology and landscape. Information was also provided on the social, environmental and

economic benefits of the proposed Development. The event took the form of a display of six large A1

boards which described the following elements of the project using both text and large images:

- Information about the developer and the benefits of Solar Energy;

- The site and its surroundings;

- Details of the proposed development;

- Layout and environmental considerations (spread across two boards); and

- Socio-Economic benefits of a solar farm and process timeline post the consultation event.

Copies of the boards can be found at Appendix A.2: Public Consultation Information.

Attendees at the community consultation event were invited to ask questions of the project team and

comment on the draft solar farm layout displayed. Attendees were also invited to fill in a questionnaire

and provide written feedback on the proposed Development. A copy of the questionnaire is included as

Appendix A.6. The feedback received informed the design and layout of the proposed Development.

Approximately 25 people attending the community consultation event and 12 people signed the

attendance sheet. 8 questionnaire forms were completed and returned to Gaelectric. The results of the

questionnaire showed a broad support for renewable energy and solar energy in particular.

In relation to Q1 – Do you support the use of renewable energy to combat climate change and ensure

the security of Irelands energy supply?, 75% of respondents answered Yes with 25% Unsure.




In relation to Q2 – Do you support the use of solar power as a source of renewable energy?, 87.5% of

respondents answered Yes with 12.5% Unsure.

In relation to Q3 – Have you ever visited a solar farm?, 62.5% of respondents answered No, 37.5%

answered Yes.

In relation to Q4 – How do you feel about our proposed plans for the Creevyquin Solar Farm?, 37.5%

of respondents answered Very Supportive, 37.5% of respondents answered Supportive, 12.5% of

respondents answered Opposed and 12.5% of respondents answered Very Opposed. In numerical

terms 6 respondents out of 8 were either Very Supportive or Supportive and 2 respondents out of 8

were Opposed or Very Opposed.

In relation to Q5 – What do you think would be the main benefits of the Creevyquin Solar Farm?, 62.5%

of respondents ticked ‘It would produce a clean and safe supply of energy’, 62.5% of respondents

ticked ‘It would help Ireland reach its renewable energy targets’, 50% of respondents ticked ‘It would

help the region to reduce its carbon dioxide emissions’, 37.5% of respondents ticked ‘it would provide

community benefits’, and 50% of respondents ticked ‘it would provide biodiversity benefits’.

Question 6 allowed respondents to state any concerns they had about the plans for the proposed solar

farm. 37.5% of respondents stated No concerns, 37.5% left the answer blank and 25% expressed

concerns. The areas of concern outlined were; glare, property price devaluation, lack of screening along

road, traffic hazard, visual impact, scale, noise, lack of national framework and change in character of

the area. The areas of concern and feedback received helped inform the design and layout of the

proposed solar farm and additional mitigation measures such as screening and layout changes were

implemented to help address concerns.

A number of local residents expressed concern about the location of the substation associated with the

proposed Development and its proximity to residential properties. In order to address this concern the

substation was moved approximately 30m north to Field 4 and is now located approximately 140m from

the nearest residential property.

Residents were also invited to contact Gaelectric should they require any further information and details

of same were provided. No further correspondence or request for further information was received.

Following the event, details of the consultation boards were uploaded to the www.gaelectric.ie website,

to allow those who couldn’t attend the event in person to access the information.

Creevquin Solar Farm Section 2

Planning and Environmental Report Planning Policy Context


2.0 PLANNING POLICY CONTEXT

2.1 INTRODUCTION

This chapter sets out the planning policy context relevant to the proposed development of a ground

mounted solar farm with associated infrastructure (“the Development”) at Creevyquin, Roscommon,

Co. Roscommon (“the Application Site”).

This section provides a brief overview of the international, national and regional legislation and policy

of relevance to the proposed Development, as well as a detailed review of the planning policy framework within which the application will be assessed.

2.2 INTERNATIONAL POLICY

2.2.1 COP 21 Paris Agreement

Ireland is legally bound by Article 7 of the United Nations COP21 Paris Agreement1, signed in December

2015, to prepare and submit periodic updates on its national adaptation and mitigation plans in the

global effort to keep global warming below 1.5 °C.

2.2.2 Renewable Energy Directive 2009/28/EC (2009)

The European Union introduced the Renewable Energy Directive2009/28/EC2 in April 2009, which sets

mandatory national targets for the overall share of energy from renewable resources and a common

framework across the EU for the promotion of renewable energy. Countries within the EU have agreed

to undertake the following:

- Reduce greenhouse gas emissions by 30% by 2020 and reduce them by 60-80%by 2050; and

- Reduce the EU’s energy consumption by 20% by 2020.

The Directive also sets targets for Member States in respect of use of energy from renewable sources.

Ireland’s legally binding obligation is 16% of energy consumption from renewable resources by 2020.

2.3 NATIONAL POLICY

2.3.1 Programme for a Partnership Government (2016)

The Programme for a Partnership Government (Oireachtas, 2016)3 dedicates an entire chapter to

climate action, stating that Ireland will be “repositioned to give global leadership in this area”. In terms

of solar and renewable energy, the document states that “We believe that Ireland’s long-term interests

are best supported by further decreasing our dependence on foreign fossil fuels through the continued

development of indigenous renewable energy” and that “we will facilitate the development of solar

energy projects”.

1 United Nations Framework Convention on Climate Change (2015) Adoption of the Paris Agreement. Available at

https://unfccc.int/resource/docs/2015/cop21/eng/l09r01.pdf [Accessed 14/10/16].

2 European Union (2009) Directive 2009/28/EC of the European Parliament and of the Council of 23 April 2009 on the promotion of the

use of energy from renewable sources. Available at: http://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32009L0028

[Accessed 14/10/16].

3Oireachtas (2016) Programme for a Partnership Government. Available at

http://www.merrionstreet.ie/MerrionStreet/en/ImageLibrary/Programme_for_Partnership_Government.pdf [Accessed 14/10/16].

https://unfccc.int/resource/docs/2015/cop21/eng/l09r01.pdf

http://www.merrionstreet.ie/MerrionStreet/en/ImageLibrary/Programme_for_Partnership_Government.pdf


Planning Policy Context Planning and Environmental Report


2.3.2 Climate Change Action and Low Carbon Development Act 2016

The Climate Change Action and Low Carbon Development Act 2016 (“the 2016 Act”) requires the

Minister for the Environment to submit to Government a national low carbon transition and mitigation

plan, to be referred to as the National Mitigation Plan (“NMP”), to be Ireland’s first statutory low carbon

strategy for the period to 2050. A primary objective of the NMP will be to bring a clear and strong focus

to both the challenges and the opportunities of transitioning to a low carbon future, and the importance

of a positively focussed and cost-effective national transition agenda. The first National Mitigation Plan

will focus on electricity generation, built environment, transport and agriculture.

2.3.3 The Draft Renewable Electricity Policy and Development Framework

The Draft Renewable Electricity Policy and Development Framework (Department of Communications,

Energy and Natural Resources, 2016)4 (“the Draft Framework”) aims to optimise Ireland’s renewable

electricity generation, both for the All-Ireland single electricity market, as well as for future potential

export markets post 2020. The Draft Framework notes the significant decrease in the cost of solar PV

panels in recent years, and suggests that solar will offer Ireland renewable generation potential in the

medium term to 2030.

2.3.4 Irelands Transition to a Low Carbon Energy Future 2015-2030

In December 2015, the Department of Communications, Energy and Natural Resources published

‘Ireland’s Transition to a Low Carbon Future 2015-20305 as the White Paper for Energy Policy in Ireland.

The White Paper sets out a vision for transforming Irelands’ fossil fuel-based energy sector into a clean,

low carbon system by 2050.Specifically the White Paper aims to reduce greenhouse gas emissions from

the energy sector by between 80% and 90% compared with 1990 levels, falling to zero by 2100.

Figure 5.2 of the White Paper illustrates that there has been a fourfold increase in the renewable energy

(%) contribution to gross final consumption since 1990.While the growth in renewable energy has been

primarily led by onshore wind and biomass, other technologies that have seen some growth in recent

years include geothermal and solar.

Figure 2.1: Renewable Energy Contribution to Gross Final Consumption

4Department of Communications, Energy and Natural Resources (2016) Draft Renewable Electricity Policy and Development Framework.

Available at http://www.dccae.gov.ie/energy/SiteCollectionDocuments/Renewable-

Energy/Draft%20Strategic%20Environmental%20Assessment%20Scoping%20Report.pdf [Accessed 14/10/16]

5Department of Communications, Energy and Natural Resources (2015) Ireland’s Transition to a Low Carbon Energy Future – 2015-2030.

Dublin: Stationery Office. Available at: http://www.dccae.gov.ie/energy/SiteCollectionDocuments/Energy-

Initiatives/Energy%20White%20Paper%20-%20Dec%202015.pdf [Accessed 01/09/06]




Paragraph 137 of the White Paper states that:

“Solar photovoltaic (PV) technology is rapidly becoming cost competitive for electricity generation, not only compared with other renewables but also compared with conventional forms of generation. The deployment of solar in Ireland has the potential to increase energy security, contribute to our renewable energy targets, and support economic growth and jobs. Solar also brings a number of benefits like relatively quick construction and a range of deployment options, including solar thermal for heat and solar PV for electricity. It can be deployed in roof-mounted or ground-mounted installations. In this way, it can empower Irish citizens and communities to take control of the production and consumption of energy. Solar technology is one of the technologies being considered in the context of the new support scheme for renewable electricity generation which will be available in 2016” (emphasis added).

2.3.5 Ireland’s Third National Energy Efficiency Action Plan to 2020

Ireland’s Third National Energy Efficiency Action Plan to 20206 (“the NEEAP”) was published in 2014.

This NEEAP sets out a strategy to reduce Ireland’s dependence on imported fossil fuels, improve energy

efficiency across a number of sectors and ensure a sustainable energy future. It concluded that by the

end of 2012 Ireland reached 39% of our 2020 target, representing primary energy savings of 12,337

gigawatt hours (“GWh”).

2.3.6 Strategy for Renewable Energy 2012-2020

The Strategy for Renewable Energy 2012-20207(“the Strategy”) reiterates the Government’s view that

the development sources of renewable energy is critical to reducing dependency on fossil fuel imports,

securing sustainable and competitive energy supplies and underpinning the move towards a low

cardoon economy, the Strategy sets out specific actions the Government will take to accelerate the

development of wind, ocean and bio-energy, R&D, sustainable transport energy and supporting energy

infrastructure.

2.3.7 The National Climate Change Adaptation Framework

The National Climate Change Adaptation Framework (Department of the Environment, Community and

Local Government, 2012)8 (“the Framework”) provides the policy context for a strategic national

adaptation response to climate change in Ireland and is designed to evolve over time as planning and

implementation progresses, and as further evidence becomes available. The Framework highlights

Ireland’s need to increase generation by solar power, as the potential for future significant deployment

falls.

2.3.8 The Sustainable Energy Authority of Ireland Strategic Plan 2010-2015

The Sustainable Energy Authority of Ireland Strategic Plan 2010-20159 (SEAI, 2010) (“the SEAI Plan”)

seeks to make Ireland a recognised global leader in sustainable energy. The SEAI Plan envisages a

future which includes electricity requirements generated entirely from indigenous renewable resources

6 Department of Communications and Natural Resources (2014) NATIONAL ENERGY EFFICIENCY ACTION PLAN 2014. Dublin: Stationery

Office. Available at: http://www.dccae.gov.ie/energy/SiteCollectionDocuments/Energy-Efficiency/NEEAP%203.pdf [Accessed 08/09/16]

7 Department of Communications and Natural Resources (2012) Strategy for Renewable Energy 2012-2020. Dublin: Stationery Office.

8Department of the Environment, Community and Local Government (2012) The National Climate Change Adaptation Framework.

Available at http://www.housing.gov.ie/sites/default/files/migrated-

files/en/Publications/Environment/ClimateChange/FileDownLoad%2C32076%2Cen.pdf [Accessed 14/10/16]

9 Sustainable Energy Authority of Ireland (2010) Sustainable Energy Authority of Ireland Strategic Plan 2010-2015.Dublin: Sustainable

Energy Authority of Ireland. Available at:

http://www.seai.ie/Publications/SEAI_Corporate_Publications_/Strategy_Documents/SEAI_5yr_strategy.pdf [Accessed 08/09/16]




and the export of electricity across Europe through an interconnected grid system. Specific Irish policy

goals include the acceleration of growth of renewable electricity from 15% of demand in 2010 to 40%

by 2020.

2.3.9 National Renewable Energy Action Plan (NREAP)10

Article 4 of Directive 2009/28/EC on renewable energy requires each Member State to adopt a national

renewable energy action plan (“the NREAP”) to be submitted to the European Commission.

The NREAP sets out the Member State’s national targets for the share of energy from renewable sources

to be consumed in transport, electricity and heating and cooling in 2020, and demonstrates how the

Member State will meet its overall national target established under the Directive to deliver 16% of

energy from renewable sources by 2020. In the electricity sector, Ireland’s renewable energy share is

40% by 2020. The significant growth in electricity from renewable sources in recent years is largely

attributable to onshore wind however other renewable technologies have seen some growth in

deployment rates.

2.3.10 National Spatial Strategy 2002-2020 (NSS)

The National Spatial Strategy11 (“the NSS”) states in relation to rural areas and renewable energy that:

- “…rural areas have a vital contribution to make to the achievement of balanced regional

development. This involves utilising and developing the economic resources of rural areas,

particularly in agriculture and food, marine, tourism, forestry, renewable energy, enterprise and

local services” (page 36); and

- “In economic development, the environment provides a resource base that supports a wide

range of activities that includes agriculture, forestry, fishing, aquaculture, mineral use, energy

use, industry, services and tourism. For these activities, the aim should be to ensure that the

resources are used in sustainable ways that put as much emphasis as possible on their

renewability” (page 114).

2.4 REGIONAL PLANNING POLICY

2.4.1 Regional Planning Guidelines for the West Region 2010 – 2022

The West Regional Planning Guidelines (“the WRG”) state the following in relation to renewable energy:

'Securing indigenous renewable energy supplies will generate a more sustainable economy,

lower carbon emissions, combat climate change and help meet national government and EU

renewable targets. It is acknowledged that the West Region can play a significant role in

delivering these targets but is reliant on the facilitation, development, reinforcement and

strengthening of the Grid to be able to connect, distribute, import and export the indigenous

land and marine renewable energy that will in future be generated'.

The WRG also state that Ireland and the West Region have the potential to become net energy

exporters through harnessing our renewable energy resources.

Section 1.5.3 Future Investment Priorities states that one of the key investment priorities required to

support the sustainable development of the region is to upgrade the energy supply and energy network

infrastructure and support Renewable Energy development.

11Department of Environment and Local Government. (2002). The National Spatial Strategy 2002-

2020: People, Places, Potential. Dublin: Stationery Office. Available at: http://nss.ie/pdfs/Completea.pdf [Accessed 01/09/16]




Objective EDO8 states 'that subject to Habitats Directive Assessment and/or other relevant

environmental assessment, support the deployment of renewable energy infrastructure in appropriate

locations'.

Under 3.6.7 Alternative employment opportunities, Policy EDP71 aims to 'Promote a green economy in

the West Region through the sustainable development of renewable energy resources'.

2.5 LOCAL POLICY

2.5.1 Roscommon County Development Plan (RCDP) 2014-2020

The Roscommon County Development Plan (“RCDP”) sets out the framework for the sustainable

development of the County. The RCDP and the associated Landscape Character Assessment supports

the development of renewable energy at appropriate locations throughout the County. Chapter 4 of

the RCDP provides a broad discussion on renewable energy and energy policies and objectives are

provided within the Plan. There are no particular locations identified for solar development.

Strategic Aim 6 aims to 'promote the role of rural areas thus maximising their economic potential in

areas such as agri –food, forestry, renewable energy and tourism'.

2.5.2 Chapter 2: Core Strategy and Settlement Policy

The Core Strategy, in line with the Regional Planning Guidelines for the West Region, recognises priority

areas in relation to economic development which will be detailed in Chapter 3 of the RCDP. Chapter 4

of the Plan details serviced land infrastructure which is vital in the support of industrial and commercial

development in both zoned lands in key towns and non-zoned lands in smaller settlements. The Core

Strategy recognises the importance of 9 no. economic strands one of which is Renewable Energy.

2.5.3 Chapter 3: Economic Development

Core Policy 2.9 aims to;

‘Identify and recognise the potential, in economic and social terms, of the county’s natural

resources such as its arable agricultural land, clean environment, lands with forestry potential,

aggregate reserves and tourism opportunities. To support the utilisation of alternative energy

provision in a sustainable and harmonious way in terms of impacts on landscapes and habitats

over the broad spectrum of its potential sources, including wind, solar and alternative fuel

sources. Any such development will be cognisant of the need to protect, conserve and enhance

the county’s biodiversity and the requirement for screening to determine if a full Appropriate

Assessment of the likely impact on integrity on Natura 2000 sites is required’.

2.5.4 Chapter 4: Infrastructure

Section 4.6 states the following in relation to renewable energy;

‘The Council recognises that the development of renewable energy offers sustainable

alternatives to our dependency on fossil fuels, a means of reducing harmful greenhouse

emissions and opportunities to reduce our reliance on imported fuels. Renewable energy comes

from natural resources that are continuously replenished by nature. The main sources of

renewable energy are the wind, the sun (solar), water (hydropower, wave and tidal energy)

heat below the surface of the earth (geothermal energy) and biomass (wood, biodegradable

waste and energy crops or bio-fuels such as rapeseed and lupines). It is the policy of the

Council to promote the generation of energy from renewable and alternative sources in an

environmentally sensitive and sustainable manner’.




In relation to Solar Energy Section 4.6.4 states;

‘In recent years the use of solar energy in Ireland in addition to ground-source heating systems

has provided sustainable sources of energy for buildings and has reduced the demand for

electricity supply from the national grid. The Council will encourage such initiatives subject to

normal planning considerations’.

Policy 4.53 under Policies on Energy aims to ‘Encourage the development of renewable energy sources

such as wind, biomass and solar energy as well as energy conservation measures such as energy-

efficient building design and servicing. All such development proposals will be assessed for their

potential impact on the environment, Landscape Character Assessment designations, compliance with

the habitats directive and other normal planning considerations. Seek to integrate climate change

considerations into development proposals’.

Under objectives on energy, Objective 4.57 aims to ‘Implement Government policy on limiting emissions

of greenhouse gasses and encourage the development of renewable energy sources in an appropriate

and sustainable manner’.

2.5.5 Chapter 9: Development Management Guidelines and Standards

Chapter 9 Table 2 provides standards and considerations in relation to key Environmental factors for

Renewal Energy development within the county.

In relation to human health it states that ‘Applications for development must demonstrate that no

significant adverse effects upon human health will occur arising from, inter alia, noise, shadow flicker

or odour’.

In relation to Cultural Heritage the following is stated;

‘Where the development is in close proximity to archaeological sites the working area shall be

kept to a minimum.

Where relevant, pre-construction archaeological investigations shall be carried out and where

necessary Archaeological Plans will be implemented including, pre-construction works,

watching briefs and excavations.

Where previously unrecorded finds are uncovered during construction, adequate archaeological

investigation and recording will be carried out before construction works in these areas are

continued’.

In relation to birds it is stated that ‘Where feasible, site clearance involving the cutting or destruction

of vegetation and hedgerows shall not take place in the bird breeding season between March 1st and

August 31st inclusive’.

2.6 Roscommon Renewable Energy Strategy 2014-2020

The Roscommon Renewable Energy Strategy (“RES”) notes that County Roscommon has the potential

to harness an extensive amount of renewable energy resources, primarily from wind, but also from

biomass and to a lesser extent from hydro and solar energy.

Under the provisions of Article 6(3) of the Habitats Directive 92/43/EEC a Habitats Directive Assessment

(HDA) was undertaken for the Roscommon RES. This was undertaken to assess the impact of the

implementation of the RES and ensure that developments arising from this Strategy would not give rise

to an adverse effect on Natura 2000 sites. The HDA determined that the implementation of the RES in

relation to bio energy, solar, heat pump/geothermal energy is unlikely to adversely affect Natura 2000

sites. The HDA also determined that hydroelectric schemes by virtue of their nature and scale could




significantly affect Natura 2000 sites, particularly sites with annexed water dependent habitats and

species.

The Strategy specify notes that to date, wind farms have dominated renewable energy developments

in Roscommon however as technology in other renewables continues to advance, it is feasible that

other forms of hydro, bio and solar energy can be developed on larger scale in Roscommon.

2.6.1 Chapter 4: Locations for Renewable Energy Development

Section 4.5 Solar and Thermal Energy

'Solar energy developments throughout County Roscommon are generally encouraged

providing they are in accordance with the principals of proper planning and sustainable

development. Solar energy development in the form of public infrastructure should be

incorporated as much as is reasonably possible e.g. solar panels on traffic warning signs.

Developments demonstrating designs incorporating solar gain, which may be as simple as

predominantly south facing glazing, are encouraged. Instances where solar energy proposals

will require careful consideration include works to a protected structure or works which may

affect a protected species or habitat for example the installation of equipment and materials

that passes through a roof void where a bat roost is located within the development'.

2.7 Landscape Character Assessment of County Roscommon

The subject site is located in Landscape Classification Area (LCA) No. 32 ‘Roscommon Town and

Hinterland’.

The zone in which the subject site is located is to the east of Roscommon Town and is classified of

‘High Landscape Value’. This classification reflects the high quality of cultural heritage features to be

found in the town environs. It is identified that outside of the town the land cover in this area is mostly

low lying dry grassland with some areas of reclaimed raised bog and forestry to the south. The rolling

drumlin hills in the north slope and drain in an easterly direction in the Hind River which connects to

Lough Reed. Shrine Hill defines the boundary in the south. Roscommon town itself has a very distinctive

character and comprises many features of important cultural heritage. There is a considerable amount

of development currently taking place on the eastern and north eastern approaches to the town,

involving mostly commercial buildings. The town is very well connected with a number of regional roads

converging in the town. The Dublin to Westport railway line also passes through this LCA.

Key Recommendations of this LCA are as follows:

'The Local Area Plan should include objectives to protect and enhance the existing character of

Roscommon Town.

The setting of the town within a rural landscape is also valuable and should be protected by a

presumption against development outside town boundaries.

Development should only be permitted where it is of the highest quality of design and will not

significantly adversely impact on the surrounding landscape character.

Three views from the town are listed in the current plan and it is recommended that a fourth

view from the entrance to the town park overlooking the turlough be listed'.

The subject site is also located in a ‘Landscape Character Type’ area and designated as ’Dry Farmland’.

Landscape Character Types are distinct landscapes that are relatively consistent in character. They are

generic in nature in that they may occur in different areas in different parts of the county, but wherever

they occur they broadly share similar combinations of geology, topography, drainage patterns,

vegetation, historical land use and settlement pattern.




2.8 CONCLUSION

At present, there is no specific national guidance for commercial solar farms in Ireland. Notwithstanding

this, the principle of solar photovoltaic is supported in the context of wider established policy relating

to the promotion and development of renewable energy.

Both the Regional Planning Guidelines and the Development Plan are considered to be supportive of

the development of renewable energy technology, particularly in the context of reducing the carbon

emissions of the country and meeting renewable energy production targets. Given that the proposed

Development is a relatively new type of development in the country there is minimal reference to them

in the Guidelines and Policies however the concept of developing renewable energy projects is

supported by the policies and guidelines therein.


Planning and Environmental Report Relevant Planning History


3.0 RELEVANT PLANNING HISTORY

3.1 LOCAL PLANNING HISTORY

There are no records on file for planning applications relating to the Application Site. The planning

history of the area is predominantly one off housing and agricultural developments. The proposed

development is not considered incongruous with the planning history of the local area.

Table 3.1 provides a summary of the recent planning history within the surrounding area.

Table 3.1 Local Planning History

Application Reference

Description Address Decision

12447 Retention for an existing dwelling house detached shed and revised site location to that as granted under previous

planning application reference No. PD/13931.

Creevyquin Roscommon

Granted -20/02/2013

09404 to construct a dwelling house and domestic garage with an advanced treatment system and percolation area and all associated ancillary site works.

Creevyquin, Roscommon

Granted - 31/08/2009

081262 To construct a dwelling house and domestic garage with an advanced treatment system and percolation area and all associated ancillary site works.

Creevyquin Roscommon

Refused - 03/03/2009

071184 to construct 4 no. horse stables, service area & storage in one covered unit, connect to existing agricultural out-buildings and all associated site development works.

Acres Td., Roscommon

Granted -17/08/2007

07549 To erect a four bay single dry shed with calving boxes on

lands.


Granted - 07/08/2007

06815 for a two storey dwelling with garage and studio over, septic tank with filter system and percolation area, including all associated site woks.


Granted - 02/08/2006

06219 For alterations to existing dwelling and construction of a new single storey extension.


Granted - 06/04/2006

0681 To demolish 1 no. single derelict building and construct 1 no. one and a half storey detached dwelling and carry out all associated site development works including provision of proprietary sewerage treatment system and percolation area.


Refused -25/09/2006Appeal to ABP – Refused -08/03/2007

3.2 OVERVIEW – SOLAR PLANNING APPLICATIONS IN IRELAND

There have been a number of recent solar farm planning applications applied for in Ireland, some of

which have been subsequently appealed to An Bord Pleanala (“ABP”). It is also noted that in addition

to the Board’s decisions, there have been a number of recent planning applications lodged for solar

farm developments in Ireland which have received permission. This section will outline the main issues

identified during the assessment of these applications.


Relevant Planning History Planning and Environmental Report


Table 3.2: Pertinent Planning History for Solar Farm Developments

Planning Authority

Planning Authority Ref

Proposed Development Planning Authority Decision

An Bord Pleanala Ref

An Bord Pleanala Decision

Waterford 16/126 Permission sought for a 10 year permission of a solar PV Energy development within a total site area of up to 28.8 hectares, to include one single storey electrical substation building and associated compound, electrical transformer/inverter station modules, solar PV panels ground mounted on steel support structures, access roads, fencing and associated electrical cabling, ducting and ancillary infrastructure at Drumroe, Cappoquin, Co. Waterford.

Granted - 05/07/16

PL93.246902 Granted - 15/11/16

Wicklow 16/176 Permission sought for a 10 year permission for a solar PV energy development on 13.76 hectares. Electrical substation, access road, fencing and ancillary infrastructure at Ballycooleen, Avoca, Co. Wicklow.

Refused – 06/04/19

PL26.246527 Granted -18/08/16

Cork 15/5424 Permission sought for a Solar PV Panel array, consisting of up 33,000 sq. metres of solar panels on ground mounted steel frames and all ancillary site development works at Knockglass and Kilberrihert, Coachford, Co. Cork.

Granted – 11/11/15

PL04.245862 Granted -16/06/16

Wexford 20140392 Permission sought for a solar PV panel array consisting of up to 36,959 sq. m. of solar panels on ground mounted steel frames and associated development in Coolroe, Tintern, Co. Wexford.

Granted – 22/12/14

PL26.244351 Granted – 09/07/15

Cork 14/06644 Permission sought for a solar PV panel array consisting of up to 5400 sq. m. of solar panels on ground mounted steel frames, electricity control room and all associated works at Ballytrasna, Lissarda, Co. Cork.

Granted – 11/02/15

PL04.244539 Granted – 07/07/15

3.3 WATERFORD COUNTY COUNCIL PLANNING REFERENCE: 16/126 – AN BORD PLEANALA

REFERENCE: PL93.246902

Under Planning Ref. 16/126, Waterford County Council issued a Notification of a Decision to Grant

Permission to Highfield Solar Limited on the 5th July 2016. The decision was subject to 1 no. Third Party

appeal.

An Bord Pleanala granted permission for the proposal on the 15th November 2016 subject to 17 no.

conditions. The key points arising from the Inspectors report are as follows:




3.3.1 Principal of the Proposed Development

In the assessment of the application, the Inspector has regard to both national and regional policy

provisions and site specific objectives. In this regard, the Government White Paper entitled “Ireland’s

Transition to a Low Carbon Energy Future 2015 – 2030”; “National Renewable Energy Action Plan

(NREAP)”; and “Renewable Energy Strategy for Waterford City & County 2016-2030’” are cited. The

Inspector concludes that “there is a general presumption in favour in both national and local policy for

developing commercial scale commercial solar farms in suitable areas on agricultural land, subject to

normal planning and environmental considerations”.

Whilst the Inspector is of the general view that there would be a significant delay before a solar farm

could be potentially brought to site as solar farms are likely to be dependent on both financial support

from the government and access agreements with ESB Networks, the Inspector notes that ”a 10-year

permission is reasonable within the policy context”.

3.3.2 EIS Requirement

The Inspector notes that “Photovoltaic solar farms are not listed as a specific use category under

Schedule 5 of the 2001 Regulations as amended”. The requirements of Part 1, Article 2 (a) are cited

and the Inspector indicates that “The proposed development is for photovoltaics, so is not by any

reasonable definition a ‘thermal’ power station and does not involve combustion, and will be of far lower

capacity than 300 MW. I do not consider that any other categories under Part 1 apply”.

The Inspector details Part, Article 3(a) and contends that his “interpretation of 3(a) is that EIA may

apply for power plants of a thermal design independent of the source of energy – i.e. if they produce

‘electricity, steam and (my emphasis) hot water’. I note that other non-thermal types of electricity

generation such as hydroelectricity and wind power are specifically included in other subsections.

Photovoltaics are not included. As the proposed development is for the production of electricity by way

of direct solar power using photovoltaics and does not involve the production of heat or hot water, I

conclude that it is does not come within this category. In any event, total output will be far below the

300MW threshold and so would be sub-threshold if 3(a) applied”.

The Inspector concludes that “a photovoltaic (non-thermal) power station such as that proposed does

not require a mandatory EIA as it does not come within any category in either Part 1 or Part 2 of

Schedule 5 of the 2001 Regulations as amended. In addition, I note that the site is not on, or in the

close vicinity of, a European site or NHA or other nature reserve or area of ecological interest. There

are no other features of particular sensitivity on the site or the immediate vicinity. I therefore conclude

that EIA is not mandatory for this proposed development and it does not come within the scope of

Article 109 of the Regulations. I conclude that EIA is not required”.

3.3.3 Residential Amenity

The Inspector describes the surrounding area and acknowledges that “there are no national standards

to assess solar PV proposals for amenity impacts. The UK policy document ‘Renewable Energy Planning

Guidance Note 2 – The Development of large scale (>50kW) solar PV arrays – Cornwall (UK) 2012’

provides some guidance, but does not provide any recommendations with regard to separation

distances”. Following an examination of the area and the surrounding properties, it is concluded that

“on the available evidence that the key issue for protecting local amenities is the control of unwanted

glint and glare from panels. The individual units are of such a size and scale that I do not consider that

there would be any overshadowing or other impact, and they would not generate noise or other forms

of nuisance or disturbance beyond what would be typical for agricultural land”.




3.3.4 Glint and Glare

With regard to Glint and Glare, the Inspector makes reference to the fact that “there is no Irish guidance

on the potential impact of glint and glare from solar panels, and no practical experience”.

The Glint and Glare Assessment submitted concluded that was an “unlikely to result in any significant

glint effects on potentially positive receptors to the north, south, east and west of the site”. The

Inspector acknowledges and concurs the conclusions of the assessment stating “I would concur with

the conclusions of the glint and glare study that any impact to the north is highly unlikely. There are

relatively few viewpoints from public areas close to the site. The south-facing panels would be facing

away from the houses along the N72, or the higher ground further north. There are no aerodromes in

the vicinity so I do not consider that there is a need to address potential aircraft safety issues”.

The Inspector highlights concern for a dwelling to the immediate south east where at its closest is 50m

from the application boundary. The Inspector notes that there is substantial hedgerow with mature

trees next to and around this dwelling and therefore does not “consider than any impact would be

particularly serious”. In this particular case and as a matter of precaution the Inspector recommends

“a condition such that no panel be placed within 100 metres of this property, and that the corner of

this site be planted with trees to a depth of at least 50 metres”.

3.3.5 Visual Impact

The Inspector notes and agrees that the landscape assessment accompanying the application is

reasonable and in accordance with the guidelines.

The Inspector acknowledges that the appeal site is in an area of agricultural land which is generally

robust and capable of absorbing modest scaled developments and “has no specific landscape

designations in the development plan”.

The Inspector recognises that the solar farm would be quite visible for anyone on the road to south

“but the existing ditch and hedge is quite thick and so I do not consider that it would be particularly

intrusive within a working agricultural landscape”. The Inspector does also not consider that the

development would be “intrusive” from the N72.

The Inspector considers “the most sensitive part of the landscape to be the area around Cappoquin,

some 4 km to the north-west”. While direct view points from around the entrance near Cappoquin

House could not be identified, it could not be ruled out that the site is directly visible from upper

windows of the house. In this regard, the Inspector notes “Notwithstanding that the farm could be

visible from viewpoints around Cappoquin, due to the orientation of the site and the panels, which

would be facing south, I do not consider that they would constitute an intrusive feature on the

landscape. I would recommend a condition such that hedgerows with trees capable of growth to at

least 3.5 metres be planted around all the site, including the northern parts where there is no boundary,

in order to soften any long distance views”.

3.3.6 Cultural Heritage

With regard to archaeological impact, the Inspector notes that “there are no records of recorded ancient

monuments or other structures on the site”. The Department of Arts, Heritage and the Gaeltacht

(“DoAHG”) requested a condition for archaeological monitoring of the works. The Inspector concurs

with the recommendation of the DoAGH and notes that “having regard to the proximity to the recorded

monument (the trackway), I consider this reasonable and recommend that it be set as a condition of

permission”.




3.3.7 Traffic

In terms of traffic impact the Inspector considers “it acceptable as a construction and maintenance

access. While there will be a significant amount of traffic during the construction period, including

possibly outsized loads during the operational period it seems unlikely that traffic would be any more

than would be normal for an agricultural operation. It may, indeed, be less. While the road to the south

is very narrow and substandard, it is used for normal agricultural operations for the farms in the area,

so I would not consider its use for occasional maintenance works to be unacceptable”.

3.3.8 Drainage and Flooding

The Inspector recognises that the site has a history of mixing arable and pasture, and such changes

would, “I consider, not be out of the usual for agricultural land that the development”. The Inspector

recommends as a precaution “a condition such that SUDS principles be applied, with swales and ponds

constructed if necessary to ensure run-off from the site is minimised”.

3.3.9 EMT

With regard to EMT, the Inspector notes that” the appellant has raised concerns about EMT emissions

from the solar panels. The evidence submitted with this (and other appeals) indicates that due to the

relatively low generating power per hectare, EMT emissions associated with solar farms are low, and

would be concentrated around the transformer connecting to the grid. Any emissions would be similar

to that associated with household electrical equipment or normal electrical power connections”.

3.3.10 Construction Impacts

The Inspector considers that” any noise, dust, or other issues relating to construction would be similar

to that for a mid-sized construction project, and subject to controls would not have amenity impacts

beyond normal construction or agricultural operations. I consider that it can be controlled by way of a

standard construction condition”.

3.3.11 Grid Connection

The Inspector states that, with regards to grid connection, “as EIA is not mandatory and the proposed

development does not fall within the requirements of Article 109 of the Regulations, I do not consider

that an assessment of any possible grid connection is required. But I would note that having regard to

the relatively low output, I would consider it very unlikely that infrastructure requirements for the solar

farm would have a significant planning impact”.

3.3.12 Ecology

The Inspector acknowledges that” the panels will involve some removal of grassland, but there will still

be sheep grazing between and below the panels. I would consider that the establishment of new and

strengthened hedgerows around the boundary, and the transition to low level sheep grazing would, if

anything, improve the ecological value of the lands”. With regard to appropriate assessment the

Inspector is satisfied that “subject to conditions and standard construction/operational controls any

impacts on either surface or subsurface water, either quantitative or qualitative, will be very minor with

no reasonable possibility of measurable impacts on the designated watercourses. Any impacts from

normal agricultural practices would likely be significantly greater”.

Overall the Inspector considers that “it is reasonable to conclude that on the basis of information on

the file, which I consider adequate in order to issue a screening determination, that the proposed

development, individually or in combination with other plans or projects would not be likely to have a

significant effect on European Site no. 002170, or any other European site, in view of the sites

conservation objectives, and so a stage 2 AA and submission of an NIS is not therefore required”.




3.3.13 Financial Contribution

The Inspector indicates that from the planning authority’s report, it was considered that “literal

application of the Scheme (which did not anticipate solar farms) would be unnecessarily burdensome

upon the applicant”. The Scheme allows for discretionary reductions in such circumstances and the

planning authority applied this. The Inspector concurs with this assessment and recommends “a

standard financial contribution condition allowing the planning authority to calculate the required

contribution as they see fit”.

3.3.14 Conclusions

Overall the Inspector concludes that “a 10-year permission for a solar farm on agricultural is a use

consistent with national and local guidelines and plans and the site is suitable for such a use subject to

conditions. The only significant alteration I would recommend is that a condition is set such that no

panels be permitted within 100 metres of a dwelling, and that the south-eastern corner of the site

(which adjoins a farmhouse and buildings) be vegetated with native trees to a depth of at least 50

metres to ensure there is no possible impact by way of glint or glare on this dwelling”.

With regard to the 100 metres setback recommendation in Condition No. 3 of the Inspectors Report, it

is noted that while the Board took due cognisance of this, the Board ultimately reduced this area to

30 metres to provide for a landscaped area with no mention of setback distances to

dwellings.

The new Condition No 3 of the Board’s Direction and Order states “A landscaped area shall be provided

at the south east corner of the site in a roughly triangular area measuring 30 metres northward from

the point shown as the South East corner of the perimeter fence and 30 metres westward from the

point shown as the South East corner of the perimeter fence.”.

3.3.15 Reasons and Considerations

The Board's Order agreed with the Inspector's recommendations and stated the following:

“Having regard to the provisions of the current development plan for the area (including the

Waterford City and County Renewable Energy Strategy 2016-2030) and to the regional and

national policy, it is considered that, subject to compliance with the conditions set out below,

the proposed construction of a solar farm would not seriously injure the visual amenities of the

area, the residential amenities of the area, or the ecology of the area. The proposed

development would, therefore, be in accordance with the proper planning and sustainable

development of the area”.

3.4 WICKLOW COUNTY COUNCIL PLANNING REFERENCE: 16/176 – AN BORD PLEANALA


Under Planning Ref. 16/176, Wicklow County Council issued a Notification of a Decision to Refuse

Permission to Highfield Solar Limited on the 6thApril 2016. The decision was subject to 1 no. First Party

appeal.

An Bord Pleanala granted permission for the proposal on the 18thAugust 2016 subject to 17 no.


3.4.1 Principal of the Proposed Development

In the assessment of the application, the Inspector has regard to both national and regional policy

provisions and site specific objectives. In this regard, the Government White Paper entitled “Ireland’s

Transition to a Low Carbon Energy Future 2015 – 2030”; “National Spatial Strategy, 2002 – 2020”; and




UK Guidelines “Planning Guidance for the development of large scale mounted solar PV systems” are

cited. The Inspector highlights that the Wicklow County Development Plan 2010-2016 “has no strategy

or guidance in relation to larger solar panel developments but does have objectives that support to

solar energy development as well as having an overriding strategy to encourage the provision of

renewable energy sources”.

Whilst the Inspector is of the general view that the acceptability of the proposal is contingent on a

range of issues such as visual impact, impact on residential amenity, environmental issues etc., the

Inspector notes that ”the proposal is acceptable in principle and the nature of use would not be contrary

to the objectives and policies either nationally or under the County Development Plan”.

3.4.2 Impact on Residential Amenity

The Inspector acknowledges that minimal noise levels may be generated at operational phase with the

main noise impact produced at construction phase, and was of the opinion that ”the construction phase

is a temporary phase and that the operational phase of the proposal will generate no noise impact” and

that “noise levels likely to be generated would be within acceptable limits and that a standard condition

requiring compliance with recommended EPA noise emission limit could be applied”. The Inspector also

notes that ”given the temporary nature of construction and appropriate construction management

restrictions including noise limits and hours of construction the proposal would be acceptable in to noise

impact”.

With regard to Glint and Glare, the Inspector makes reference to An Bord Pleanala Ref. PL26.244539

report where it was stated that “the issue of glare is not particularly relevant to solar panels”. Despite

the Inspector recognising that “the applicant has provided no information regarding potential impact of

the development in regards to glint”, the Inspector states that “I would note that vegetation would

mitigate against any glint impacts and in general” and ”Overall I would consider that given the low

potential occurrence of glint from the proposed development and the nature of the landscape that the

proposed development would not have any significant impacts on the surrounding area in relation to

glint and glare”.

Overall, the Inspector recognises that impacts such as noise, dust, traffic and general disturbance are

mainly at the construction stage and as such ”are temporary in nature and can be dealt with through

adequate construction management”. Furthermore, the Inspector notes that ”the operational phase of

the proposal is unlikely to have an adverse impact on residential amenity given the passive nature

activity”.

3.4.3 Landscape / Visual Impact

The Inspector acknowledges that the appeal site is located in an area designated as an Area of Special

Amenity and as being a gateway to the more upland areas classified as Areas of Outstanding Natural

Beauty. The Inspector recognises that the visual impact of the proposal is an important consideration

however notes that ”the designation of the area as such does not necessarily preclude development if

it can be demonstrated that such would have an acceptable visual impact”.

The Inspector concurs with the conclusions of the Landscape and Visual Impact Assessment that the

development would not have a visual impact beyond the 5km radius identified in the Zone of Theoretical

Impact. It was considered that the visual impact within the 5km zone was not significant and the overall

visual impact is constrained to the immediate locality of the site.

Furthermore, the Inspector recognises that site coverage of the proposed development is likely to entail

a significant visual change to the character of the landscape. Notwithstanding such, the Inspector

acknowledges that the solar panels themselves are low profile structures and the proposal has allowed

for new hedgerow boundaries. Having regard to this, the Inspector notes that ”given the localised

nature of the visual impact, which would not be unacceptable in the context of the adjoining local road




and from existing dwellings in the vicinity, I would consider that the overall visual impact of the

development would be acceptable”.

With regard to specific adjoining local roads and views and prospects including scenic routes identified

under the County Development Plan, the Inspector considers that the “proposal is satisfactory in

regards to visual impact and landscape character”.

3.4.4 Traffic

In terms of traffic impact the Inspector was “satisfied that the existing road network would be capable

of facilitating construction traffic for the proposed development. I would also note that the construction

period is a temporary period and therefore traffic levels would not be an ongoing issue given that the

operational phase is likely to consist of maintenance only”.

In terms of traffic safety, it was considered that the layout and visibility at the proposed entrance to

the site and the junction between the L2180 and the L6171 to be satisfactory to deal with the traffic

movements likely to be generated including both the construction and operational phases.

3.4.5 Ecology

The Inspector considered that ”the ecological impact of the proposal would be acceptable and that the

proposal given the nature of structures and low level of hard surfacing it entails would not significantly

alter the characteristics of the site so as to adversely impact existing ecology”. Furthermore the

Inspector notes that the lands adjacent to the site are of similar character and would provide for suitable

habitats in the immediate vicinity for any species displaced.

3.4.6 Surface Water Drainage

It is recognised that the development would increase surface water run-off on the site however given

the scale of the hard surface areas in relation to the overall site it is not anticipated that the operational

phase of the development would generate any significant additional surface water. The Inspector is

”satisfied that an appropriate condition can deal with this mater and that the actual change to the

drainage characteristics of the land are minimal”.

3.4.7 EIS Screening

The Inspector notes that ”I have examined the Part 1, Schedule 5 projects and I would not consider

that a solar farm is included in any of these project descriptions. I have also examined the Part 2,

Schedule 5 projects and although I would note that there are some projects under Paragraph 3 ‘Energy

Projects’ which relate to energy production. I would consider that none of these projects would be

applicable to a solar farm as proposed. In reaching this conclusion I would have regard to the most

recent solar farm developments before the Board, i.e. appeal reference No.s PL04.244539 and

PL26.244351 and PL04.245862, where a similar conclusion was reached in each case……As I have

considered above that the solar panel development is not a development set out in Schedule 5 then I

would not consider that the subject development is a ‘sub-threshold development’ for the purpose of

EIS”.

3.4.8 Noise

The Inspector states that, with regards to noise, “it is noted that all manufacturing is to be carried out

off site with no welding or cutting machinery to be used. Construction noise levels will meet best

practices standards”.




3.4.9 Archaeology

With regard to archaeological impact, the Inspector notes that ”there are no recorded monuments

within the confines of the site and the applicant did provide an archaeological assessment of the site.

I am satisfied that an appropriate condition requiring archaeological monitoring is sufficient to deal with

this issue”.

3.4.10 Other Issues

The applicant requested that the duration of the planning permission would be for ten years. The

Inspector concurs and suggests a condition to formalise this decision.


The Board's Order agreed with the Inspector's recommendations and stated the following:

“Having regard to the nature, scale and location of the proposed development, to the

separation distances to European Sites, and to the lack of potential for connectivity with those

sites, the Board is satisfied that the proposed development either individually or in combination

with other plans or projects would not be likely to have significant effects on European Sites

having regard to the conservation objectives of these sites. The Board accepted the assessment

of the Inspector on this matter and shared his conclusions.

Having regard to the nature, characteristics, scale and location of the proposed development

and to the characteristics of its potential impacts, the Board is satisfied that the proposed

development would not be likely to have significant effects on the environment, and concurred

with the analysis and conclusion of the Inspector on this matter in relation to environmental

impact assessment.

Having regard to the nature and scale of the proposed development, the suitability of the

aspect and topography of the site, the proximity of the grid connection, the pattern of

development in the vicinity, the provisions of the Wicklow County Development Plan 2010 –

2016, and of regional and national policy objectives in relation to renewable energy, it is

considered that, subject to compliance with the conditions set out below, the proposed

development would have acceptable impacts on visual amenity, would not seriously injure the

residential amenities of property in the vicinity, and would be in accordance with the proper

planning and sustainable development of the area”.

3.5 CORK COUNTY COUNCIL PLANNING REFERENCE: 15/5424 – AN BORD PLEANALA


Under Planning Ref. 15/5424 Cork County Council issued a Notification of a Decision to Grant Permission

to Trainman Ltd. on the 11th November 2015. The decision was subject to 2 no. First Party appeals.

An Bord Pleanala granted permission for the proposal on the 16thJune 2016 subject to 18 no. conditions.

The key points arising from the Inspectors report are as follows:

3.5.1 Principle of Development

The Inspector notes that” while such developments may have a positive outcome in terms of national,

regional and county objectives” other issues pertaining to the impacts of the development need to be

taken account of. However, the Inspector is of the opinion that ”there would be a general positive

consideration towards solar panel developments in remote rural marginal agricultural land provided

that the proposed development would not adversely impact on the established environmental and

residential amenities of the local area”.




3.5.2 Impact on Residential Amenity

In terms of noise associated from the construction activities, the Inspector notes that ”I would consider

that the construction noise, subject to compliance conditions, from the proposed development would

be acceptable……Overall I would consider that operational noise from the proposed development is not

a significant issue”.

With regard to the issue of privacy, the Inspector accepts ”that there will be impacts on established

amenities during construction period however this will be temporary in nature”. The Inspector makes

reference to the UK Guidelines ‘Planning Guidance for the development of large scale mounted solar

PV systems’, which include a consultation with the police service who recommend a CCTV system as a

defence mechanism and notes that the ”utilisation of CCTV cameras is an important feature of solar

farms in the interest of crime prevention”. The Inspector is of the opinion that the CCTV system would

prevent crime and therefore protects privacy in the general area and concludes that ”the operational

phase of the proposed development is essentially self-operational, apart from maintenance visits and

therefore I would consider that the proposed development would not significantly impact on the

residential privacy in the local area”.

With regards to property values, the Inspector highlights that claims of devaluation are not

substantiated with any evidence or studies and states that “I would consider that the site in question

is subject to development potential as is any other site in the local area and there is no basis that

proposed development would devalue house values in the local area more so than any other

development that maybe permitted on the site”.


The Inspector makes reference to appeal ref. PL04.244539 report where it was stated that the ”issue

of glare is not particularly relevant to solar panels and this was the same conclusion reached in the

submitted Planning and Environmental Report in the current appeal before the Board”.

In terms of glint, it is noted that the applicant submitted a Planning and Environmental Report which

outlined that the proposed solar panels are very dark in colour and they are designed to absorb light

rather than reflect light. In this regard, the Inspector considers that ”given the low potential occurrence

of glint from the proposed development as outlined by the applicant, the sparsely populated local area

and the nature of the landscape that the proposed development will not have any significant impacts

on the surrounding area in relation to glint and glare”.

3.5.4 Landscape and Visual Impact

The Inspector highlights that the site is effectively a local hill-top and that the highest elevation of the

site is 311m O.D. The appeal site nor its environs is not located within a designated ‘High Value

Landscape’ however there is a designated Scenic Route situated relatively close to the appeal site. In

this regard, the Inspector notes that ”although the designated Scenic Route is situated relatively close

to the appeal site the proposed development would have no adverse impacts given the local

topography, i.e. the Burren hill-top which is situated between the proposed development and the Scenic

Route and would screen any views from the Scenic Route to the subject site.…”. In general the Planning

and Environmental Report which accompanied the planning application concludes that the proposed

development integrates visually with the established landscape, and the Inspector states that “I would

generally concur with this conclusion however I would note that view no. 4 possibly represents the

most distinct change”. The Inspector further adds that ”the appeal site is located within an area that is

designated ‘open for consideration’ for wind farm development and as such some level of change can

be expected to the local landscape”.

The Inspector concludes by noting that it is considered that the ”proposed development would alter

the established landscape from a visual perspective, however the established landscape, given the




undulating nature, is relatively variable and capable of absorbing change in my view. Therefore in

conclusion, it is my view, based on the information available and having regard to the nature of the

established landscape and the absence of any landscape designations that the proposed development

would not adversely impact on the landscape and visual amenities of the area”.

3.5.5 Traffic and Access

The Inspector was of the opinion that based on the information available, that the ”applicant has

adequately demonstrated that the delivery route would be adequate to accommodate the proposed

construction traffic”. It is further stated that ”I would consider that the applicant has adequately

demonstrated that the traffic generation associated with the proposed development, during both

construction and operational phase, would not adversely impact on the established road network”.

3.5.6 Ecology

In terms of ecology the Inspectors states that ”I would consider that on the basis that the local habitat

has no ecological designation and that there is available alternatives in the area that the impacts on

the habitats, i.e. largely scrub and gorse, would be acceptable. In addition I would consider that the

likely impacts on birds and mammals would be acceptable given the availability of alternative habitats

in the immediate area”.

3.5.7 Surface Water Drainage

It is noted that the proposed development will result in limited additional hard surface areas. This would

include the upgrading of the existing track, which is currently a soft track, a new proposed track to the

north of the site and temporary laydown area. The Inspector ”accepts that these developments would

increase surface water run-off on the site however given the scale of the hard surface areas in relation

to the overall site I would not anticipate that the operational phase of the proposed development would

generate any significant additional surface water”.

The Inspector ‘concurs’ with the conclusion of the Area Engineers report that ”considers that surface

water drainage proposals are acceptable ”and indicates that ”having regard to nature of the

development proposed, that the development would not have significant impacts on surface water

drainage”.

3.5.8 Appropriate Assessment Screening

The application documentation includes an Appropriate Assessment Screening which confirms that no

conservation designation applies to the subject site. Section 2.2 of the Ecology Report outlines a number

of conservation designations that are located within a 15km radius of the appeal site. The Inspector

acknowledges ”the conclusions of the AA Screening Report and the report by the Local Authority

ecologist that the proposed development is unlikely to have significant effects on any Natura 2000 site

as there is effectively no ecological connectivity between the proposed development and the Natura

2000 sites ”and concludes ”that on the basis of the information on the file, which I consider adequate

in order to issue a screening determination, that the proposed development, individually or in

combination with other plans or projects would not be likely to have a significant effect on any European

Site listed above, in view of the sites conservation objectives and a stage 2 AA is not required”.

3.5.9 EIS Screening

With regards to EIA Screening, the Inspector states ”I have examined the Part 1, Schedule 5 projects

and I would not consider that a solar farm is included in any of these project descriptions. I have also

examined the Part 2, Schedule 5 projects and although I would note that there are some projects under

Paragraph 3 ‘Energy Projects’ which relate to energy production I would consider that none of these

projects would be applicable to a solar farm as proposed. In reaching this conclusion I would have




regard to the two most recent solar farm developments before the Board, i.e. appeal ref. 244539 and

appeal ref. 244351, were a similar conclusion was reached.……As I have considered above that the

solar panel development is not a development set out in Schedule 5 then I would not consider that the

subject development to be ‘Sub-threshold Development’……overall I would conclude, based on the

information on the file, that the proposed development is not likely to have significant effects on the

environment and that an E.I.S. would not be warranted in this case”.

3.5.10 Other Issues

In terms of health issues, the Inspector refers to the nearest receptors and their respective distances

from the proposed development (between 360m-540m for that application) and considers ”that these

dwellings are located a sufficient distance from the inverters to prevent any health impacts”.

It is argued by the appellants that the proposed solar development is premature pending the publication

of national guidelines. It is noted that there is no indication of any national guidelines in the near future

and the Inspector acknowledges ”that planning permission is sought for many types of development

without guidelines and this would be no different for the proposed development”.

With regard to planning maps and public consultation, the Inspector is satisfied that ”the applicant has

submitted that application in accordance with the requirements of the Planning and Development

Regulations, 2001, and I would concur with this conclusion”.


The Board stated in their reasons and considerations: -

”Having regard to the nature, scale and location of the proposed development, to the

separation distances to European Sites, and to the lack of potential for connectivity with those

sites, the Board is satisfied that the proposed development would not be likely to have

significant effects on European Sites. The Board adopted the assessment of the Inspector on

this matter and shared his conclusions.

Having regard to the nature, characteristics, scale and location of the proposed development,

and to the characteristics of its potential impacts, the Board is satisfied that the proposed

development would not be likely to have significant effects on the environment, and concurred

with the analysis and conclusion of the Inspector on this matter.

Having regard to the nature and scale of the proposed development, the suitability of the

aspect and topography of the site, the proximity of the grid connection, the pattern of

development in the vicinity, the provisions of the Cork County Development Plan 2014 and of

regional and national policy objectives in relation to renewable energy, it is considered that,

subject to compliance with the conditions set out below, the proposed development would not

seriously injure the visual amenities of the area or the residential amenities of property in the

vicinity, and would be in accordance with the proper planning and sustainable development of

the area”.

3.6 WEXFORD COUNTY COUNCIL PLANNING REFERENCE: 20140392 – AN BORD PLEANALA


Under Planning Reg. Ref. 20140392, Wexford County Council issued a Notification of a Decision to

Grant Permission to Ms Sarah O' Flaherty on the 22ndDecember 2014. The decision was subject to 4

no. Third Party appeals.

An Bord Pleanala granted permission for the proposal on the 9thJuly 2015 subject to 14 no. conditions.

The key points arising from the Inspectors report are as follows:




3.6.1 Policy Context

The Inspector notes that the proposed development “is supported in broad terms by the policies of the

Regional Planning Guidelines and County Development Plan in the areas of renewable energy

development and rural diversification”.


The Inspector acknowledges that the issue of glint and glare was a 'new issue' for the Irish Planning

System. Essentially the Inspector outlined that “when the sun is low in the sky - morning and evening

-, light can reflect from the surface of panels to ground based observers to the west and east,

respectively. As with the issues of noise and shadow flicker for wind turbines, the potential effects on

receptors can be modelled at planning stage, and indeed is often done as a matter of course in the UK,

on foot of their guidelines”.

The Inspector was of the view that the (glint and glare) study submitted identified potential impacts at

two properties and that “screening and planting is cited as being a mitigation measures ”which was

considered “sufficient to mitigate against impacts on ground floor and ground level receptors, in my

opinion”.

3.6.3 Visual Impact

With regards to middle range visual impacts, the Inspector concurs "with the applicant's brood

contention that there would be visual containment by hedgerows and topography in middle range

views”. It was further outlined by the Inspector that “there would be some potential views from R734,

but fleeting and oblique, and not necessarily unpleasant, given the orientation”.

The Inspector set out that the Landscape and Visual Impact Assessment (LVIA) submitted with the

proposal “asserts that the form would be difficult to discern beyond 5km. Having viewed o number of

existing solar forms in the UK, this is consistent with my experience”.

3.6.4 Land Use - Loss of Agricultural Land

The Inspector outlines that while in the UK agricultural land was classified in terms of quality, “there is

no objective classification of the quality of agricultural land for planning purposes, nor am I aware of

any relevant planning policies against which this metric could be assessed”.

The Inspector did not consider that the growing of high value crops in the past on lands would be

grounds for refusing permission and acknowledged that sheep grazing was to be introduced on the site

which was consistent with solar farms in the UK.

3.6.5 Noise

With regards to noise, the Inspector outlines that “the applicant's response that the unwavering

consensus among design consultants and contractors is that this solar panels or mounting structures

do not cause noise. I can find no credible evidence that suggests that noise is on Issue with so/or

forms. While there might be some electrical hum from the plant buildings, these ore located on the

western fringes of the site, away from any sensitive receptors”.


The Inspector notes that the applicant had applied for a preliminary grid agreement with ESB Networks.

With regards to the inclusion of the grid connection with the planning application and issues relating to

windfarms the Inspector states ”that as no requirement for EIA arises, no issues arise in the area of

grid connection on foot of the recent 'O'Grianna' court judgement on this topic”.




3.6.7 EIA Screening

The Inspector comments that the (Wexford) Planning Officer “concludes that Environmental Impact

Assessment is not required. Nevertheless, the board is also required to 'screen' for EIA, under the

provisions of Article 109 of the Planning and Development Regulations 2001 (as amended)”.

The Inspector concludes that ”On the basis of the above assessment, I do not consider that the

proposed development is 'subthreshold development' for the purposes of EIA. As such, it is not

necessary to continue to the criteria set out in Schedule 7 of the regulations. I have also consulted the

EIA directive itself, and can see no additional considerations that could be brought to bear on this

question”.

In addition, the Inspector considers that “were the Schedule 7 criteria to be applied to the proposed

development, I do not consider that the requirement for EIA would have been triggered due to the

nature of the proposed development and its location”. The Inspector also outlines that “it would appear

that the EIA requirements in the UK go above and beyond what is required by the EU Directive, and

indeed as is currently required in Ireland”.

3.6.8 Conclusions of Inspector

The Inspector was satisfied that the proposed setback of 22m from the boundaries of (adjacent)

residential properties was an appropriate balance between the competing interests of the appeal

parties. Furthermore, with regards to glint and glare the proposed planting, orientation and extent of

glint and glare predicted was such as not to be unacceptable. The proposed additional planting was

considered to mitigate the short range visual impact and that medium and long range views would be

acceptable.

The proposed foundation methodology was considered to be a relatively 'light tough' impact on the

soil, and is reversible. There would be no significant impacts on drainage patterns. A restoration plan

was recommended. In addition, the Inspector considered that the proposed development would have

a relatively benign impact on ecology subject to appropriate provision for the movement of mammals

at ground level.

With regards to the grid connection the Inspector noted that although not explicitly specified in the

application, it was not seen as an impediment to a grant of permission. The Inspector further considered

that there was “no requirement for EIA”.


The Board's Order generally agreed with the Inspector's recommendations and stated the following: -

”Having regard to the provisions of the current development plan for the area and to the

regional and national policy, it is considered that, subject to compliance with the conditions set

out below, the proposed construction of a solar farm would not seriously injure the visual

amenities of the area, the residential amenities of the area, or the ecology of the area. The

proposed development would, therefore, be in accordance with the proper planning and

sustainable development of the area. (Emphasis added).

In reaching its decision, the Board noted and concurred with the Inspector's view thot the

Environmental Impact Assessment was not required in respect of this development, and that

the development would not be likely to have on significant impact on the environment. The

Board also noted the Inspector's analysis under the heading of Appropriate Assessment, and

agreed with the Inspector that, having regard to the separation distance between the subject

site and the nearest European sites -the Bannow Bay Special Area of Conservation (Site Code

000697), the Bannow Boy Special Protection Area (Site Code 004033) and the River Barrow

and River Nore Special Area of Conservation {Site Code 002162) the development, by itself or




in combination with other plans or projects, would not be likely to have a significant effect on

these European sites, in view of the site's conservation objectives. The Board, therefore,

adopted the Inspector's conclusions in relation to these two matters”. (Emphasis added).

3.7 CORK COUNTY COUNCIL PLANNING REFERENCE: 14/06644 – AN BORD PLEANALA

REFERENCE: PL 04.244539

Under Planning Reference 14/06644, Cork County Council issued a Notification of a Decision to Grant

Permission to Reeve Wind Ltd. on the 11th February 2015. The decision was subject to 4 no. Third

Party appeals.

An Bord Pleanala granted permission for the proposal on the 7th of July 2015 subject to 13 no.


3.7.1 Visual Assessment

The Inspector was of the view that while the appearance of the array in the landscape “will certainly

be a departure from anything which exists at present”, it was pointed out that there were a number of

activities/uses which can have a visual impact (temporary or longer term) such as the ploughing of a

field, laying of clear plastic on fields to increase soil temperatures, glasshouses, & Polytunnels.

Similarly, the Inspector considers that the proposed fencing “will not have any impact on the visual

amenities of the area”.

3.6.2 Environmental Impact Assessment

The Inspector highlights that the proposed development “does not come within any class specified in

the Planning Regulations 2001 (as amended)”. It was further commented that “Having regard to the

limited nature of the development, the absence of any nature conservation designations in the

immediate area, the absence of any emissions from the development and the absence of any connection

to watercourses, it must be concluded that the development will not have a significant impact on the

environment”.

The Inspector further outlines that” References made to 'project-splitting' in the absence of indication

as to how the development is to be connected to the electricity grid, are not relevant considerations,

as EIA would not be required in the first instance”.

3.7.3 Reasons and Consideration

The Board stated in their reasons and considerations:

“Having regard to the provisions of the current Development Pion for the area and of notional

renewable energy policy, and having regard to the limited scale of the proposed development.,

the pattern of development in the vicinity, and the proposals to screen the boundaries of the

proposed site, it is considered that, subject to compliance with the attached conditions, the

proposed development would not seriously injure the residential amenities of property in the

vicinity, and would not detract from the visual amenities of the area. The proposed

development would, therefore, be in accordance with the proper planning and sustainable

development of the area.

In reaching its decision, the Board noted and concurred with the Inspector's view that the

Environmental Impact Assessment was not required in respect of this development, and that

the development would not be likely to have a significant impact on the environment. The

Board also noted the Inspector's analysis under the heading of Appropriate Assessment, and

agreed with the Inspector that, having regard to the separation distance between the subject

site and the nearest European sites - the Gearagh Special Protection Area (Site Code 004109)




and the Gearagh Special Area of Conservation (Site Code 000108), the development, by itself

or in combination with other plans or projects, would not be likely to have a significant effect

on these European sites, in view of the site's conservation objectives”.

3.8 CONCLUSION

It is evident from the above that the assessment of solar farm developments in Ireland is now well

established and that the main planning related issues and mitigation measures have been set out in

the cases above by the Board. This has provided a template for the nature and extent of the information

deemed appropriate for inclusion in a planning application for a solar farm development.

The technical and environmental detail submitted in this planning application has had cognisance to

the information required and submitted as part of the appeals process.


Planning and Environmental Report Site Location & Project Description


4.0 SITE LOCATION AND PROJECT DESCRIPTION

4.1 OVERVIEW

Planning consent is being sought by Gaelectric Renewable Energy Developments Ltd (“the Applicant”)

for the development of a solar photovoltaic (“PV”) energy development to include: a single storey

electrical substation building, electrical inverter and transformer stations, solar PV panels mounted on

metal frames, new access tracks, underground cabling, perimeter fencing with infrared CCTV and access

gates, temporary construction compound, spare parts container, weather station, a new access point

and all ancillary infrastructure and associated works within a total site area of up to 34 acres.

The site is located at Creevyquin, Roscommon, Co. Roscommon (“the Application Site”).

The Applicant is requesting a planning permission that is effective for 10 years and has an operational

period of 30 years.

At the end of its operation all infrastructure will be decommissioned, dismantled and removed from the

site. The Development is low impact, and represents a temporary use in the landscape, which is fully

reversible in nature.

Legal agreements with the landowner of the Application Site are in place and the proposed Development

is to be sited entirely within these lands.

The final detailed design of the Development may have some minor variations to the infrastructure defined

in the planning application. This will generally be due to the specific requirements of the site, discovered

via ground investigation works, or as dictated by final design drawings prepared by the Engineer, Procure,

Construct ("EPC') contractor. An over-riding principle will be that any minor differences will be kept to a

minimum, and only implemented where absolutely necessary. Please refer to Section 4.6 Design

Approach for a proposal of how the Applicant proposes to address this issue within the planning

application.

4.2 SITE LOCATION

The Application Site is situated on agricultural lands in the townland of Creevyquin, approximately

1.9km east of Roscommon Town. The site is unzoned and is located approximately 710m north-east

from the closest land use zonings associated with the Roscommon Local Area Plan 2014 – 2020.

The Application Site lies at an elevation of approximately 50 – 58m AOD and is centred on National Grid

Reference E589905 N764677. The site is bounded to the south by the L7122 (L1811) local road. The

proposed Development will be contained within five fields of varying sizes. The fields are comprised

predominately of grazed agricultural grassland pasture. The fields and surrounding landscape are

predominantly flat in nature.

Field boundaries consist predominantly of hedgerows and treelines. Figure: ‘Site Location Plan’

(located in the Schedule of Planning Drawings) refers.

There are a number of residential dwellings in proximity to the Application Site, however all of these

dwellings are located well beyond the 22m distance considered appropriate in the technical assessment

made by the An Bord Pleanala Inspector under PL 26.244351.


Site Location &Project Description Planning and Environmental Report


4.3 SITE CRITERIA SELECTION

The Application Site selection for solar is influenced by a range of factors, the most significant of

which are outlined below:

- Solar Resource: Solar resource varies across Ireland – yields in this part of Roscommon are

sufficiently;

- Grid Infrastructure proximity: Solar projects should be located near to suitable grid connection

points. The Development is located a suitable distance from a substation suitable to accommodate

a project of this scale;

- Residential Dwelling proximity: Solar projects should be located a suitable distance away from

residential properties. The closest property is located approximately c.38m from the property edge

to the fenceline and approximately 55m from the nearest solar panel array associated with the

proposed Development;

- Landscape: Careful siting of the solar arrays and associated site infrastructure has formed part of

the Landscape and Visual Assessment (“LVIA”). The views of the Development are extremely limited

and contained with the screening proposed as an appropriate mitigation measure. Section 6:

Landscape and Visual Impact Assessment and Appendix F: Landscape and Visual Impact

Assessment refer;

- Ecology: Solar projects should be screened for Appropriate Assessment and ecological surveys

should be conducted at optimum times of year. Phase 1 Habitat surveys have been conducted and

Appropriate Assessment has been screened out. A full ecological assessment details the findings of

the same has been completed. Section 5: Ecological Appraisal and Appropriate Assessment

Screening, Appendix C: Ecological Appraisal, Appendix D: Appropriate Assessment

Screening Report, Appendix E: Outline Construction Environmental Management Plan

and Appendix L: Tree Survey Report refer;

- Soils, Hydrology and Geology: A Soils, Hydrology and Geology Assessment and Stage 1 Flood Risk

Assessment were conducted to identify any potential environmental constraints to the proposed

Development. Section 9: Hydrology, Geology and Flood Risk Assessment and Outline

Construction Environmental Management Plan, Appendix K: Hydrology, Geology and

Flood Risk Assessment and Appendix E: Outline Construction Environmental

Management Plan refer;

- Archaeology: Solar projects may impact directly or indirectly on scheduled monuments or protected

structures and unknown archaeology. There are no scheduled monuments located within the

Application Site. One possible area of archaeology occurs within Field 4, a small possible enclosure,

which could also be the trace remains of a relict field boundary. An archaeology assessment has

been carried out to assess existing archaeology in the surrounding area. Section 7: Archaeology,

Architectural & Cultural Heritage Assessment and Appendix I: Appendix I Archaeology

Architectural Heritage Cultural Heritage Impact Assessment refer; and

- Alternatives: A screening assessment was completed of the Roscommon Town region, and this site

was selected having regard to suitability criteria.

4.4 SURROUNDING AREA

The largest settlement closest to the Application Site is the town of Roscommon, which is the county

town of Roscommon. The town contains a mix of historical, residential, recreational, commercial and

industrial areas. Land Use in the surrounding area outside of the town consists primarily of agricultural

land and one off housing with some ribbon development occurring along local roads. The Application




Site is approximately c1.9km east of Roscommon Town. A capped landfill occurs 175m to the north of

the Application Site.

4.5 INFRASTRUCTURE

4.5.1 Solar Panels and Mounting Frames

Photovoltaic solar panels will be orientated toward the south on galvanised metal mounting frames.

Panels will be angled at between 20 and 30 degrees to maximise daylight capture, and will be fixed in

place with no moving parts.

The panels will be mounted on a simple galvanised metal framework and will have a maximum height

of between approximately 1.7 metres (“m”) and 2.8m. Panels will be raised at between approximately

0.7m and 0.9m above ground level at their lowest point, allowing vegetation to grow beneath the

panels.

The glass surfaced panels are coated to maximise daylight absorption, and thus minimise glare

potential. The proposed solar panels do not produce noise.

Indicative designs of the solar panels and mounting arrangements are shown in Figure Gaelectric-

Solar-001 ‘Indicative Solar Panel Table Layout Plan & Elevations’. Each table is expected to

comprise 2 rows of up to 24 solar panels. The rack variants proposed include arrangements of up to 2

panels in portrait position or up to 4 panels in landscape position. The number of spacing of panel

mounting posts will vary depending upon ground conditions. The final arrangement will be subject to

detailed design, however a single post rack and a two post rack indicative design are shown. The

mounting structure will be capable of withstanding appropriate environmental stresses for the location,

such as wind or snow loading.

The panel tables will be separated by a distance of between 3.5m and 7.0m, to allow operational access

and to ensure that one panel does not cast a shadow over another.

The mounting frames will be made of either galvanised aluminium or steel and will have a rough matt

(rather than polished) finish. The diameter of each post of the mounting frame is approximately 0.1m.

Posts will be either screw-piled or direct driven into the ground to a depth of up to 1.5m and, as such,

do not require any excavation works. The posts / piles are designed to avoid the use of concrete

foundations. If required in areas of the Application Site where piling is not appropriate, foundations can

comprise a pre-cast concrete footing. A typical structure of the type proposed for the Development is

shown in Plate 1.1: Typical Mounting Structure.

Solar panels will be set back distances of at least 50m from residential dwellings to ensure that there

is no impact to residential amenity.




Plate 1.1: Typical Mounting Structure

4.5.2 Inverter and Transformer Stations

Up to 3no. inverter and transformer stations will be installed. Each station will either be a single

structure (with maximum dimensions of 9.2m in length by 3.2m in width and 3.45m in height) or two

separate adjacent structures (each with maximum dimensions of measuring 6.2m in length by 3.2m in

width and 3.45m in height). The structures will be of a container design, of either metal or a glass

reinforced plastic (“GRP”) construction, and will be painted in a green finish. The final design and

selection will depend on the manufacturer, and to ensure that best in class technology is used at the

time of construction. The final design will be agreed with the planning authority prior to commencement

of construction. The inverter and transformer stations will arrive on site in pre-manufactured form and

set on a concrete plinth or a granular sub-base of compressed stones. A typical structure of the type

proposed for the Development is shown in Plate 1.2: Typical Combined Inverter and

Transformer Station.

The inverter and transformer stations are connected to the solar panels by cabling which will be buried

underground. The panels themselves generate Direct Current (“DC”) electricity which is converted into

Alternating Current (“AC”) before being fed into the substation and then into the local distribution

network.

An aerial or satellite dish will be affixed to the inverter / transformer cabins as required to monitor

performance remotely.

Whilst the solar panels themselves are not noise producing, the inverter / transformer stations emit

only a very low level of noise. The majority of the external noise is created by the air conditioning unit

needed to keep the inverter cool. A noise assessment of the Development has been completed, and is

shown at Appendix B: Noise Assessment. This infrastructure has been positioned away from

residential receptors to ensure no impact on residential amenity. Figure Gaelectric-Solar-002

‘Indicative Inverter / Transformer Plans & Elevations’ refers.




Plate 1.2: Typical Combined Inverter and Transformer Station

4.5.3 Substation Building

Figure Gaelectric-Solar-003 ‘Indicative ESB and Client Substation’ details the dimensions of

the substation building. The proposed building will be a block structure with a fine rendered finish and

a tiled pitch roof, and will consist of an ESB Room, a Switchgear Room and a Metering and

Telecommunications Room. The building dimensions are approximately 10.7m by 5.4m by 4.7m. The

final appearance and dimensions of the substation may alter due to the current requirements of ESB

Networks. The substation has been located approximately 140m away from the nearest residential

property following feedback at the community consultation event.

The purpose of the new substation is to house the required ESB Networks metering and control

equipment, along with the switchgear from the solar farm and a control room for the solar farm control

equipment. Cables connecting the substation with the rest of the Development will be placed

underground in narrow trenches at a depth of approximately 1.0m. These trenches will be refilled

immediately on cable laying and reseeded.

4.5.4 Fencing and Security

Fencing is proposed to secure the Application Site. It is proposed that the fencing is located along the

perimeter of the solar PV area, as shown in Figure: ‘Master Site Layout Plan’ and all associated site

layout plans. Space will be left between the fence and field boundaries (for agricultural access and

ecological enhancement) and between the fence and solar panel array for Development maintenance

and access. Fence posts will be mounted on concrete foundations. Superior premium wire deer fencing

or similar will be erected to a maximum height of between approximately 1.8m and 2.0m. Separate

gates will provide access into the solar array fields. The gates will be constructed of wire steel mesh




and will have an access width of between approximately 4.0m and 6.0m. Figure Gaelectric-Solar-

004 ‘Indicative Deer Fence and Gate Details’ refers.

CCTV cameras will be interspersed along the fencing perimeter. Spacing between cameras will be

dependent upon the specification of cameras used and specialist contractor design requirements

(proposed locations are shown on Figure: ‘Master Site Layout Plan’ and all associated site layout

plans.). CCTV units will be mounted on galvanised posts incorporating an anti-climbing guard for

enhanced security. The posts will be between approximately 4m and 4.5m above ground at their highest

point. No security lighting is proposed as infrared cameras will be used. Cameras will be directed into

the Development, and so will not impinge on the privacy of local properties. Figure Gaelectric-Solar-

005 ‘Indicative CCTV Mast Elevation’ refers.

4.5.5 Weather Station

The Development may also include a Weather Station, as per the indicative design on Figure

Gaelectric-Solar-006 ‘Weather Station’. This infrastructure is likely to be required to monitor

prevailing meteorological conditions, which will help to ensure that the Development is performing

optimally. Tower height will not exceed 5.0m, however the type and orientation of equipment may vary

from this outline design.

4.5.6 Spare Parts Container

A spare parts container will be retained on site during the operational stage of the Development. Storing

limited supplies of spare parts will reduce the need for small lorries and vans to visit the Development.

An indicative design in shown onFigure Gaelectric Solar-007 ‘Spare Parts Container’.

4.5.7 Access and Site Tracks

The Development will be connected to the public road network at the L7122 (L1811) local road via a

new entrance point. Figure 3 of Appendix J: Construction Traffic Management Plan refers.

Following consultation with Roscommon County Council, it has been confirmed that suitable visibility

splays can be achieved with some clearance of vegetation to achieve sightlines. The access design has

been informed by the guidance specified by Roscommon County Council1 in regards to hedgerow

alteration for road safety and set back of hedgerows;

‘It is also possible to move or translocate the existing hedgerow and replant it back the distance

required to achieve safe sight lines’.

Additional and upgraded access tracks will be constructed to allow access to the solar panels, substation

and inverter / transformer buildings.

Tracks will be between 3.5 and 4.5m wide. All new tracks would be unpaved and constructed from local

stone. A geotextile / geogrid would be laid, except where the track was being laid directly onto a rock

base, to minimise the need for stone and to reduce the impact on soils. The track would then be built

up on the geotextile by layering and compacting granular material (crushed rock) up to a total maximum

thickness of up to 0.5m dependent on the ground conditions.

Track drainage will nominally comprise a ditch formed on the upslope side of the track (dependent on

a detailed drainage design). All tracks would have adequate cross-slope to allow rainwater to be shed.

Where the track slopes steeply downhill, waterbars or drainage grips would be installed on the track

surface to divert runoff into track drainage. Silt traps or other settlement features would be installed

where track drainage ditches discharge to a watercourse. If any new surface water drains and shallow

1 http://www.roscommoncoco.ie/en/Services/Heritage/Publications/LandscapingYourHousewithNativeSpecies.pdf ,Page 5 [Accessed 10.01.2017]

http://www.roscommoncoco.ie/en/Services/Heritage/Publications/LandscapingYourHousewithNativeSpecies.pdf




perched water are identified during geotechnical site investigation and/or during construction works,

these will be incorporated into the design of access track drainage. Water would either be diverted

into trackside drains, or simple piped culverts would be used to allow water to cross the track in order

to preserve existing flows coinciding with existing drainage paths.

There are different specifications for access track construction dependant on the slope of the ground

perpendicular to the track. These require different designs as detailed on Figure Gaelectric-Solar-

008 ‘Indicative Road Construction Details’ (1) and Figure Gaelectric-Solar-009 ‘Indicative

Road Construction Details’ (2).

Load bearing crane hardstanding areas are required during construction to support the cranes as they

lift the inverter and transformer stations from the delivery vehicles. Generally, the site tracks can be

used for this purpose, with some localised widening where required.

The access tracks will be left in place after completion of the solar farm construction, as they will

provide:

- Access for the Development maintenance and repair works;

- Access for the Landowner; and

- Access for decommissioning of the Development.

Once decommissioned, any new access tracks will also be removed.

4.5.8 Temporary Construction Compound

A temporary construction compound will be required during the construction phase of the Development.

The proposed location of the compound is shown on the submitted infrastructure layout drawing and

measures an area of approximately 58m x 42m. The location is away from any watercourses or

ecologically sensitive areas. An indicative design of a typical temporary construction compound is

shown in Figure Gaelectric-Solar-010 'Indicative Temporary Construction Compound' and

will temporarily store:

- Temporary cabin (Port-a-Cabin type) to be used for site office and welfare facilities including welfare

facilities with provision for sealed waste storage and removal;

- Container storage unit(s) for tool and equipment storage;

- Temporary cabin (Port-a-Cabin type) to be used for site office and welfare facilities including welfare

facilities with provision for sealed waste storage and removal;

- Container storage unit(s) for components and materials;

- Refuelling compound for construction vehicle and machinery;

- Chemical toilets;

- Adequate parking area for cars, construction vehicles and machinery; and

- Designated skips for construction waste.

The compound area will be stripped of topsoil, which would be stored separately for future

reinstatement, then surfaced with stone to provide an adequate vehicle load-bearing surface.

Management of oils and fuels shall be as per best practice pollution prevention guidelines; the area of

the compound used for the storage of fuel and oils will be contained by a small bund constructed out

of site arising material and lined with an impermeable membrane in order to prevent any contamination

of the surrounding soils, vegetation and water table. In addition, double protection containers /

equipment will be used along with drip trays. Water for all construction activities will be supplied by




water bowser. Temporary effluent disposal facilities would be provided by 'portaloo' type facilities and

emptied as required. No mains sewers or water pipes are proposed. Once construction of the

Development is completed all portacabins, machinery and equipment will be removed and hardstanding

excavated. The area will be re-graded with the stockpiled topsoil to a natural profile and allowed to

regenerate from the seed bank within the topsoil.


The connection point to the ESB Networks (“ESBN”) distribution system will be at the on-site substation

building.

It is currently proposed that the Development will connect into the ESB network via the 38kV

Roscommon substation by means of approximately 1.6 km of underground cable via an indicative route

following the local road network. A second alternative indicative route has been also proposed by means

of approximately 1.5 km of underground cable or overhead line.

The connection to the electricity grid will however be subject to the technical and safety requirements

of ESBN and will be subject to a separate planning application (if required).

The preliminary design has therefore also considered an overhead line or underground cable route via

adjacent fields to the point of connection. Indicative routing is shown on Figure: ‘Indicative Grid

Connection Routes’ (located in the Schedule of Planning Drawings) refers.

The likely impacts of the indicative connection routes have been assessed and are considered

representative of similar alternatives. For clarity, this planning application does not include the grid

connection, however the likely impacts of the proposed indicative connection routes have been assessed

in the technical assessments accompanying this document, and are considered to be representative of

similar alternatives.

4.5.10 Berm

A new berm approximately 1 -1.5m high is proposed at the site entrance and along the south west

boundary of the Application Site, with planting of hedgerows and trees along it and screen planting

along its base. The height of the berm is related to soil stability and the difficulty of constructing a berm

of greater than 1 to 1.5m without some retaining elements. The 1.5m berm and screen planting along

it will provide screening of views into the Application Site from the roadside and residents opposite the

site entrance, helping to reduce visual impact of the solar farm development.

Figure 7C Viewpoint 3 demonstrates that the combination of the berm and structural mitigation planting

appropriately screens views of the development from residents opposite.

4.6 DESIGN APPROACH

As mentioned in Section 4.1, the final detailed design of the Development may have some minor

variations to the infrastructure to be outlined in the submitted planning application. An over-riding

principle will be that any minor differences will be kept to a minimum, and only implemented where

absolutely necessary. This approach follows best practice in the UK and Northern Ireland.

Geotechnical surveys and detailed design will inform the location of site tracks, inverter and transformer

stations, substation, temporary storage compound, fencing, CCTV cameras and panels / racks, but at

all times they will be located within 15m of that shown on the attached site layout plans.




To ensure Roscommon County Council approval of the final detail design and layout, Gaelectric

proposes the following pre-commencement condition (see also Section 11: Suggested Conditions):

“No development shall commence until a detailed design plan showing the final position and

layout of the panels, electrical equipment and associated infrastructure is submitted to and

approved in writing by Roscommon County Council. The development shall thereafter be

constructed in accordance with the approved plans”

4.7 OPERATION AND MAINTENANCE

The proposed Development will be generally unmanned during the operational phase and will be

monitored remotely during its lifetime. During the operational period, the proposed Development only

requires occasional visits for maintenance of the infrastructure and grounds.

4.8 CONSTRUCTION AND DECOMMISSIONING

This proposed Development is anticipated to take up to 3-4 months from inception to completion. This

process will be governed by strict environmental controls, as well as health and safety procedures. The

civil works themselves are non-invasive, reflecting the temporary nature of the proposed development.

An Outline Construction Environmental Plan (“OCEMP”) accompanies this application (Appendix E)

and outlines how the proposed Development will avoid, minimise or mitigate any effects on the

environment. In addition, a detailed Construction Management Plan (“CMP”) will be submitted prior to

commencement.

In the event of a grant of permission Gaelectric proposes the inclusion of a condition with the following

wording suggested (see also Section 11: Suggested Conditions):

“Prior to commencement of the development, a Construction Management Plan shall be

submitted to the planning authority for written agreement. This plan shall provide details of

intended construction practice for the development.”

The proposed Development is temporary and will have an operational lifetime of 30 years. At the end

of its operation all infrastructure will be decommissioned, dismantled and removed from the site. Upon

decommissioning the solar farm and associated infrastructure will be removed and the land will be

returned to its former use. In the event of a grant of permission Gaelectric proposes the inclusion of a

condition with the following wording suggested (see also Section 11: Suggested Conditions):

“Prior to commencement of the development, a detailed restoration plan, providing for removal

of foundations and access roads to a specific timescale shall be submitted to the planning

authority for written agreement. The site shall be restored in accordance with the said

programme and all decommissioned structures shall be removed within six months of

decommissioning”.

4.9 BENEFITS

4.9.1 Overview

The proposed Development will generate energy from renewable sources (solar radiation). Depending

on the technology available at the time of construction, the Development can be expected to provide

in the region of 4,466 megawatt hours (“MWh”); enough clean green electricity to meet the average

electricity consumption equivalent of 890 homes. As such, the Development will make a significant

contribution towards helping achieve Ireland’s 40% target for renewable energy by 2020.




Table 4.1: Contribution to Policy Objectives

Factor Contribution of Creevyquin Solar Farm

Energy Produced (MWh per annum) 4,466

Number of Homes Powered (per annum) 8902

CO2 Reductions (kg per annum) 2,0413

The proposed Development will have a number of other social, economic and environmental benefits,

as outlined below.

4.9.2 Economic Benefits

The capital cost of the construction of the Development (that has the potential to be spent within the

Irish economy) has been estimated at approximately €1.36 million. Whilst Ireland doesn’t currently

have a proven supply chain of the solar panels, local expenditure can be expected on infrastructure

such as electrical and civil balance of plant, security equipment, grid costs and project management.

Operational expenditure in the region of €94,000 per annum (business rates, community fund

payments, grid costs, landowner rents, management and administration etc.), is also expected to be

spent locally. The total economic benefit of the Development therefore has the potential to provide

over €4million of regional and local economic benefit over the proposed 30 year operational lifetime.

Business consultancy KPMG has assessed a number of global studies that have investigated the job

creation potential of solar4. The report notes that for Ireland “with, at present, little of the solar PV

supply chain in Ireland most of those jobs will be in construction and installation of solar PV capacity,

with some additional jobs in operating and maintaining the plants”. Using 2017 figures from the KPMG

report, the Development can be expected to provide 23 Full Time Equivalent (“FTE”) jobs for the

construction period and 2 FTE jobs for the 30 year operational phase;

Other economic benefits include increased security and reliability of supply through more distributed

generation closer to the point of use and less power wastage in transmission over long distances.

4.9.3 Environmental Benefits

Environmental benefits include:

- Reducing carbon emissions: in the long term, reduced carbon emissions are expected to contribute

to a deceleration in the rate of global climate change;

- Air quality improvements: renewable energy proposals have indirect benefits in this regard through

their contribution to reduced fossil fuel emissions; and

- Improved biodiversity: The ELMP identifies management measures which aim to provide both

screening for the Development and to enhance the ecological corridors and improve the biodiversity

already present at the Application Site. These measures include; planting a nectar rich wildflower

2 Sustainable Energy Authority of Ireland (2013) Energy in the Residential Sector 2013 Report. Dublin: Sustainable Energy Authority of

Ireland. Page 48 notes "In 2011, the “average” dwelling consumed 19,875 kWh of energy, based on climate corrected data, 4.4% below

the 2010 level. This comprised 14,858 kWh (75%) direct fossil fuels and 5,016 kWh (25%) of electricity." Therefore, the Development is

expected to meet the average electricity consumption of 890 homes.

3 Sustainable Energy Authority of Ireland (2013) Energy in the Residential Sector 2013 Report. Dublin: Sustainable Energy Authority of

Ireland. Page 48 notes "The carbon intensity of electricity fell by 49% since 1990 to a new low of 457 g CO2/kWh in 2014" and "The

efficiency of electricity supply increased to 49.1% in 2014 while emissions from electricity generation fell to a record low of 457 g

CO2/kWh". The expected generation (4,466 MWh) is multiplied by 0.457 to calculate the KG of CO2 equivalent saved per year.

4 KPMG (2015) A Brighter Future: The Potential Benefits of Solar PV in Ireland. Available at

http://www.kpmg.com/ie/en/issuesandinsights/articlespublications/pages/a-brighter-future-solar-pv-ireland.aspx [accessed 06/09/2016].




mix between the perimeter fence and the nearest natural boundary, planting a mixture of fine

grasses and nectar rich wildflowers within the grassland under and between the solar arrays, the

creation of an 8 to 10m Drainage Buffer Zone adjacent to the existing drainage channel at the site

which aims to allow the development of herbaceous sward of wet grassland/marsh species which

already occur in this area and also the creation of a swale which aims to help attenuate overland

flows but will also provide benefits to wildlife (see Appendix G: Ecological Landscape

Management Plan and Appendix C: Ecological Impact Assessment).

4.9.4 Social Benefits

Social benefits include:

- Opportunities for use of the Development as an educational resource, leading to a wider awareness

of renewable energy, increased interest in environmental issues and an increased sense of

environmental stewardship among the local population; and

- The UK Department of Environment and Climate Change (“DECC”) regularly publish public attitude

trackers towards renewable energy. Solar has, over the years, consistently topped the table in

terms of public support for renewable technologies. The 2015 ‘Wave 13’ survey5showed that 81%

of people surveyed supported the use of solar.

5 https://www.gov.uk/government/statistics/public-attitudes-tracking-survey-wave-13


Planning and Environmental Report Ecological Impact Assessment & A.A. Screening

Gaelectric Renewable Energy Developments Ltd Page 5-1

January 2017

5.0 ECOLOGICAL IMPACT ASSESSMENT AND APPROPRIATE ASSESSMENT

SCREENING

5.1 OVERVIEW

Woodrow Ecology has been appointed by Gaelectric to complete an Ecological Impact Assessment

(“EcIA”) and to carry out an Appropriate Assessment Screening for the development of a proposed

solar farm with associated infrastructure (“the Development”) on lands at Creevyquin, Roscommon, Co

Roscommon (“the Application Site”).

This section summarises (and should be read in conjunction with) the full Technical Appendix -

Appendix C ‘Ecological Impact Assessment’ and Appendix D ‘Appropriate Assessment

Screening’ refer.

5.2 ECOLOGICAL IMPACT ASSESSMENT

5.2.1 Surveys Conducted

Ecology surveys within a defined Ecological Survey Area (“ESA”), which encompassed the Application

Site, were undertaken following specific guidelines for the relevant target species.

5.2.2 Impact Assessment

Table 5.1 summarises the assessment of potential impacts at the Application Site from the proposed

Development.

Table 5.1: Summary of Predicted Impact

Natura 2000

sites

The Application Site is not located within any Natura 2000 sites and is not ecologically or hydrologically

connected to a Natura 2000 site. There is no potential for impact on any Natura 2000 site as a result

of works associated with the Application Site.

A screening for appropriate assessment report has been undertaken for the proposed Development

including the Indicative Grid Connection Routes. This report has concluded that there is no potential for

significant impacts on either the Lough Ree SAC or the Lough Ree SPA.

Treelines

Treeline habitat within the Application Site will be felled and trimmed during the construction stage of

the proposed Development. This will include:

- Approximately 6 trees (and 70m of hedgerow) will be removed along the southern boundary of the

Application Site in order to accommodate the Developments entrance and provide sightlines. This

treeline consists primarily of maturing specimens of ash.

- 175m of discontinuous treeline, consisting of 27 semi-mature to early-mature ash and two semi-

mature hawthorns will be felled on the north-eastern side of the Application Site. This treeline has

been classified as Category C as per BS5837:2012 and is considered to have limited conservation

value (see the Tree Survey Report – Appendix L).

- 3 small sections of treeline will need to be removed to accommodate the proposed access tracks.

These include:

- Approximately 5m of treeline will be felled between field 2 and 3.

- 5m will be felled between field 3 and 4 beside an existing gap to accommodate the proposed access

track.


Ecological Impact Assessment & A.A. Screening Planning and Environmental Report

Page 5-2 Gaelectric Renewable Energy Developments Ltd

January 2017

- Approximately 5m of treeline will be felled between field 4 and 5.

- Small sections of treeline habitat may need to be trimmed or felled in the 5 locations where the

proposed security fence crosses these features.

It is considered that, in the absence of appropriate mitigation, there is the potential for a negative impact of high magnitude on the feature of local conservation value, resulting in a potential negative impact of moderate significance. The potential impact is certain, and permanent.

Hedgerows/

Wet

Grassland/

Scrub/

Hedgerows:

Two small sections of Hedgerows (WL1) will need to be felled to accommodate the proposed Access

tracks within the Application Site boundary. The proposed access tracks are approximately 3.5m wide.

As such any removal of hedgerow habitat at each point will unlikely be more than 5m and will likely be

less than this on the boundary between Field 1 and Field 5 (see Appendix D: Figure 9).

It is considered, in the absence of appropriate mitigation, there is the potential for a negative impact of

moderate magnitude on a feature of local conservation value, resulting in a potential negative impact of

minor significance. The potential impact is certain, and temporary (long-term).

Wet Grassland:

A significant proportion of the proposed infrastructure will be located on the area which is classified as

Wet grassland (GS4). The proposed sub-station, 2 of the proposed inverter / transformer stations, the

proposed spare part container, berms and approximately 530m of proposed site tracks will result in a

direct loss of Wet Grassland (GS4) for the duration of the Development. The solar panels will be mounted

on a frame which will be anchored to the ground via posts which will be screw-driven or pile driven into

the ground. Consequently, there will be a minimal loss of this wet grassland due to the installation of

the solar array.

The temporary site compound will also result in a temporary loss of Wet grassland (GS4) as will the

proposed buried cables. The area of the temporary site compound and the buried cables will, however,

be reinstated with vegetation after works are completed.

It is considered that, in the absence of appropriate mitigation, there is the potential for a negative impact

of moderate magnitude on a feature of local conservation value, resulting in a negative impact of minor

significance. The potential impacts range from temporary (short-term), probable and reversible, to

permanent, probable and reversible.

Scrub:

The area classified as scrub along the northern boundary of the Application Site (north of field 1) will

not be impacted by the development as no infrastructure will be located within this area of habitat. A

set-back distance of 5m from this habitat has been incorporated into the design phase of the proposal.

The construction of a security fence and the exclusion of grazing animals from this area of habitat will

likely result in the further development of woody scrub species and the development of an understory

to the existing stand of mature trees within this area. Also, the area in this habitat which contains

relatively mature specimens of willow Salix sp. but currently has no shrub layer and an impoverished

field layer is likely to become more diverse in its character and develop ‘woodland’ structure.

Consequently, it is considered that there is potential for the proposed development to have a positive

impact of low magnitude on a feature of local conservation value, resulting in a potential positive impact

of minor significance. This potential impact is considered to be probable.

Birds

The proposed Development will result in changes to the vegetation structure within the Application Site.

For example, as cutting will no longer be feasible at the same scale around the solar panels, it will have

to be done using smaller machinery and/or the area will have to be grazed. As it is unlikely to be grazed

by cattle, due to their size and inability to graze under the panels, there will likely be an improved

structure to the improved grassland habitat for ground nesting birds.

It is considered that, in the absence of appropriate mitigation, there is the potential for a worst case

negative impact of moderate magnitude on a feature of local conservation value, resulting in a potential




January 2017

negative impact of minor significance. The potential impact is temporary (long term), probable, and

reversible. For some species, the potential impact will be neutral or positive.

Bats

Only one species was confirmed at the Application Site during the current survey and the activity

recorded was minimal. However, the habitats within the Application site, particularly the linear habitats

such as treelines and hedgerows, and the area of scrub along the northern side of the site were deemed

to be potentially suitable for commuting and feeding bats.

A survey conducted on the 20/10/16 also aimed to identify the suitability of the trees within the site for

roosting bats. Two cavities potentially suitable for roosting bats were identified in trees within the

Application Site, however, no signs of use by bats was recorded at these cavities. Also, no cavities

suitable for bats roosts were identified in any of the trees/treelines which are proposed for felling and

cutting.


of moderate magnitude on a feature of local conservation value, resulting in a potential negative impact

of minor significance. The potential impact is temporary (long term), probable, and reversible.

Terrestrial

Mammals

Badger scat and feeding signs were recorded at the site during the current surveys. Security fencing

around the PV arrays could create a barrier to the movement of wild mammals such as Badger,

hedgehog, fox etc. around or through the Application Site.


of low magnitude on a feature of local conservation value, resulting in a potential negative impact of

minor significance. The potential impact is temporary (long term), likely, and reversible.

Herpetofauna Although common frogs Rana temporaria or smooth newt Lissotriton vulgaris were not recorded at the

site, the drainage channel along the southern boundary of the Application Site does have the potential

to support them. Consequently, potential water quality impacts on this feature have the potential to

impact on the suitability of this habitat for these species.


of low magnitude on a feature of local conservation value, resulting in a potential negative impact of

minor significance. The potential impact is temporary (long term), unlikely, and reversible.

Invasive

Alien Species

No invasive alien species were recorded within the Application Site boundary. The works do not include

any proposal to bring spoil or organic material into the site. There is no potential for impacts resulting

from the spread of alien invasive species.

Although the Planning Application does not include a grid connection route, some of the technical

assessments, including the EcIA, includes a review of anticipated cable routes for completeness. Two

Indicative Grid Connection Routes – Option 1 and Option 2 are considered.

5.2.3 Mitigation

Following a best practice approach, mitigation has been put forward to reduce or avoid potential for

impact on important and sensitive ecological receptors, including designated sites, and priority species

and habitats. Although some mitigation is ‘embedded mitigation’ which has included avoiding buffer

zones to surrounding habitats or watercourses, a full mitigation for each impact is detailed in Appendix

‘C’ ‘Ecological Impact Assessment’. Mitigation measures are also summarised and graphically

portrayed on Appendix G ‘Ecological and Landscape Mitigation Plan’ (“ELMP”).




January 2017

5.2.4 Conclusions

The unmitigated potential impacts caused by the proposed Development range from negative impacts

of moderate significance which are permanent in duration, in the case of treelines temporary (short

term) impacts to negative moderate permanent impacts (on treeline habitat within the Application Site).

It is concluded that, without mitigation, the Development has the potential to result in negative impacts

of negligible significance which are temporary (short-term to long-term) in duration to impacts of

moderate significance which are permanent in duration. The most notable negative impact occurs on a

Category C treelines within the Application Site with a section of approximately 175m of discontinuous

treeline being removed which consists of 27 semi-mature ash Fraxinus excelsior and 2 semi-mature

hawthorns Crataegus monogyna. Other areas of treeline and hedgerow will be cut and trimmed to

accommodate infrastructure, such as access tracks, and to create sufficient sightlines at the proposed

access to the Application Site. The proposed felling and cutting of treeline and hedgerow habitats has

the potential to result in impacts on the local bird assemblage and reduce available foraging habitat for

bats.

Mitigation measures have been proposed to address these identified impacts and provide enhancement

to the Application Site where this is possible. These measures include restrictions of tree and hedge

felling/cutting to outside of the breeding bird season, planting hedgerows and screening belts of native

tree species to replace lost habitat and to enhance existing treelines and hedgerows, bringing the

hedgerows in the site under an ecologically sensitive management regime, planting a species rich

grassland, planting a wildflower margin, creating a drainage buffer zone and the creation of one swale.

As a consequence of the proposed mitigation the potential for residual impacts on the receptors at the

site will range from negative impacts of minor significance which are temporary (short-term to long-

term) to positive impacts of minor significance which are temporary (long-term).

5.3 APPROPRIATE ASSESSMENT SCREENING

Woodrow Sustainable Solutions undertook ecological surveys of the Application Site and wider area in

order to inform a Screening for Appropriate Assessment (Appendix D ‘Appropriate Assessment

Screening’ of the Planning and Environment Report refers). This Statement provides the information

necessary to fulfil the requirements of Article 6 of the EU Habitats Directive 1992 and Regulation 42 of

the (Birds and Natural Habitats) Regulations 2011 in determining the potential impacts on Natura 2000

sites of the proposal.

5.3.1 Natura 2000 sites within 15km of the Application Site

The Application Site does not lie within, or adjacent to, any Natura 2000 site. The closest Natura 2000

site to the location of the proposed Development is the Lough Ree SAC. However, there is no potential

for direct ecological or hydrological connections between the proposed Development at the Application

Site and the Lough Ree SAC or any other Natura 2000 site within 15km.

The drainage ditch within the Application Site is situated within the Hind River sub-catchment and

ultimately drains into the Creevyquin Stream (a tributary of the Hind River). However, given the size of

the drainage ditches and the typically slow movement of water through these features the potential

connectivity between the Application Site and the Creevyquin Stream (and consequently the River Hind

and Lough Ree) is considered indirect and negligible.

Indicative Grid Route Option 1 and Option 2 both have potential hydrological connections with the

Lough Ree SAC and Lough Ree SPA.




January 2017

5.3.2 Assessment of Likely Impacts affecting the Lough Ree SAC

5.3.2.1 Direct Impacts - Application Site

The Application Site is not located either within or adjacent to any Natura 2000 site. The closest Natura

2000 site, the Lough Ree SAC, is located 1.4 km distant from the Application Site. Therefore, it can be

concluded that there is no potential for direct impacts of the proposed Development upon any Natura

2000 site.

5.3.2.2 Direct Impacts - Indicative Grid Connection Routes

Although the planning application does not include a proposed grid connection route, two Indicative

Grid Connection Routes (Options 1 and 2) have been considered as part of this proposal for

completeness. However, neither of the Indicative Grid Connection Route options passes through, or

adjacent to, any Natura 2000 site including the Lough Ree SAC which is located approximately 1.8km

to the south east. Therefore, it can be concluded there is no potential for direct impacts upon the Lough

Ree SAC resulting from the Indicative Grid Connection Routes Option 1 or 2.

5.3.2.3 Indirect Impacts - Application Site

The Application Site does not have any hydrological or ecological connections to any Natura 2000 sites.

Consequently, there is no pathway for potential impacts to any Natura 2000 sites, including the Lough

Ree SAC, and as such there is no potential for significant impacts caused by the proposed Development.

5.3.2.4 Indirect Impacts - Indicative Grid Connection Routes



completeness.

The Lough Ree SAC is designated for a number of Annex I habitats. Most of the Annex I habitats for

which this site is designated, namely Semi-natural dry grasslands and scrubland facies on calcareous

substrates (Festuco-Brometalia) (* important orchid sites) [6210], Degraded raised bogs still capable

of natural regeneration [7120], Alkaline fens [7230], Limestone pavements [8240], Old sessile oak

woods with Ilex and Blechnum in the British Isles [91A0], and Bog woodland [91D0], provide no

pathway for potential impacts from the Indicative Grid Connection Option 1 and Option 2 as they are

either terrestrial or hydrologically separated from Lough Ree. However, the Indicative Grid Connection

Route Options 1 and 2 are considered to have a potential hydrological pathway to the Annex I Habitat,

Natural eutrophic lakes with Magnopotamion or Hydrocharition - type vegetation [3150] and the Annex

II species Otter Lutra lutra [1355] which occur at the designated site.

It is considered that any grid connection route is likely to include the trenching of cables or the

installation of an overhead line. Any trenching works may lead to surface water run-off contaminated

with sediment created by the excavation works and/or hydrocarbons from the associated machinery.

However, any trenching works are likely to be small in scale and any sediment deposition resulting from

these works will be temporary. Also as these impacts will occur 16km upstream of the Lough Ree SAC

it is considered that any water quality impacts are likely to be negligible on reaching Lough Ree. Both

the Annex I Habitat, Natural eutrophic lakes with Magnopotamion or Hydrocharition - type vegetation

[3150] and the Annex II species Otter Lutra lutra [1355] are sensitive to deterioration in water quality

(NPWS, 2016). However, as the magnitude of any water quality impacts generated by the trenching of

cables in existing roadways is negligible it is considered that there is no potential for significant impacts




January 2017

either the Annex I Habitat, Natural eutrophic lakes with Magnopotamion or Hydrocharition - type

vegetation [3150] or the Annex II species Otter Lutra lutra [1355]. Consequently, there is no potential

for significant impacts on the Lough Ree SAC caused by the Indicative Grid Routes, Option 1 or Option

2.

5.3.3 Assessment of Likely Impacts affecting the Lough Ree SPA

5.3.3.1 Direct Impacts - Application Site

The Application Site is not located either within or adjacent to any Natura 2000 site. The closest Natura

2000 site, the Lough Ree SAC is located 1.4km distant from the Application Site. The Lough Ree SPA is

located 5.1km from the Application Site. Therefore, it can be concluded there is no potential for direct

impacts of the proposed Development upon any Natura 2000 site including the Lough Ree SPA.

5.3.3.2 Direct Impacts - Indicative Grid Connection Routes



completeness. However, neither of the Indicative Grid Connection Route options pass through, or

adjacent to, any Natura 2000 site including the Lough Ree SAC which is located approximately 1.8km

to the south east. Therefore, it can be concluded there is no potential for direct impacts upon the Lough

Ree SPA resulting from the Indicative Grid Connection Routes Option 1 or 2.

5.3.3.3 Indirect Impacts - Application Site

The Application Site does not have any hydrological or ecological connections to any Natura 2000 sites.

Consequently, there is no pathway for potential impacts to any Natura 2000 sites, including the Lough

Ree SPA, and as such there is no potential for significant impacts caused by the proposed Development.

5.3.3.4 Indirect Impacts - Indicative Grid Connection Routes



completeness.

The Indicative Grid Connection Route Option 1 and Option 2 crosses the Creevyquin Stream via a road

bridge on the N63. The Creevyquin Stream is a tributary of the River Hind which it joins less than 2km

downstream of the bridge which the Indicative Grid Connection Route Option 1 crosses. The River Hind

flows into Lough Ree approximately 16km downstream of the crossing. Consequently, the Indicative

Grid Connection Route Option 1 has a direct hydrological connection with the Lough Ree SPA.

The Lough Ree SPA is designated for a number of nationally important populations of wintering

waterfowl, namely Little Grebe, Whooper Swan, Wigeon, Teal, Mallard, Shoveler, Tufted Duck,

Goldeneye, Coot, Golden Plover and Lapwing. A number of other species of conservation interest have

also been recorded at the site such as Great Crested Grebe, Cormorant, Curlew and Black-headed Gull

as well as the resident Mute Swan. Greenland White-fronted Goose are also known to occur within the

site.

It is considered that any grid connection route is likely to include the trenching of cables and/or the

installation of an overhead line. The trenching works may lead to surface water run-off contaminated

with sediment created by the excavation works and/or petro-chemicals from the associated machinery.




January 2017

However, any trenching works are likely to be small in scale and any sediment deposition resulting from

these works will be temporary. Also as these impacts will occur 16km upstream of Lough Ree it is

considered that any water quality impacts are likely to be negligible on reaching this waterbody.

Therefore, it considered that there is no potential for significant impacts on the Annex I bird species

for which the Lough Ree SPA is designated or on the wetlands on many of which these species depend.

Consequently, there is no potential for significant impact on the Lough Ree SPA.

5.4.4 Potential for Cumulative Impacts

It has been concluded that there is no potential for impacts on the Natura 2000 network caused by the

proposed Development. It has also been concluded that there is no potential for significant impacts

caused by Indicative Grid Connection Route Option 1 or Option 2 on the Natura 2000 network.

Consequently, there is no potential for significant impact caused by the cumulative impacts of the

proposed Development and the Indicative Grid Connection Routes.

5.3.4 Conclusion of Screening

It is concluded that there is no potential for the proposed Development to impact on any

Natura 2000 site. The Application Site does not occur within or adjacent to any Natura

2000 sites. The closest Natura 2000 site is the Lough Ree SAC which is approximately

1.4km to the east. Also, there is no ecological or hydrological connection between the

Application Site and any Natura 2000 sites and as such there are no potential pathways for

the Development to indirectly impact on any Natura 2000 sites.

Although no grid connection route has been proposed with the current Application, two Indicative Grid

Connection Routes are being considered with this Application for completeness. Consequently, both

Indicative Grid Connection Routes have been considered throughout the current screening report.

Embedded environmental controls following Best Practice Guidelines in relation to construction works

near watercourses will further reduce the potential for such impacts on the Creevyquin stream and

Lough Ree. Consequently, it is concluded that there is no potential for significant impacts

on the conservation interests of the Lough Ree SAC or the Lough Ree SPA.


Planning and Environmental Report LVIA and Glint & Glare


6.0 LANDSCAPE AND VISUAL IMPACT ASSESSMENT AND GLINT & GLARE

6.1 OVERVIEW

Neo Environmental Ltd has been appointed by Gaelectric Renewable Energy Developments Ltd. (“the

Applicant”) to provide a Landscape and Visual Impact Assessment (“LVIA”) and a Glint and Glare

Assessment of a proposed solar farm with associated infrastructure (“the Development”) on lands at

Creevyquin, Roscommon, Co Roscommon (“the Application Site”).

This section summarises (and should be read in conjunction with) Appendix F: Landscape and

Visual Impact Assessment, Appendix G: Ecological Landscape Mitigation Plan and Appendix

H: Glint and Glare Assessment.

6.2 LANDSCAPE AND VISUAL IMPACT ASSESSMENT (“LVIA”)

6.2.1 Pre-Application Consultation

Pre-application discussions on the proposed Development were undertaken by Neo Environmental with

Jennifer Collins, Planning Officer of Roscommon County Council at the County offices on the 3rd August

2016. During the meeting the proposed approach to the LVIA and potential representative viewpoint

locations were discussed with the Council.

6.2.2 Planning Precedent

The conclusions drawn from the following An Bord Pleanala appeals in relation to visual impact are

noted:

6.2.2.1 Wicklow County Council Planning Reference: 16/176 – An Bord Pleanala Planning

Reference: PL26.246527

The Inspector acknowledges that the appeal site is located in an area designated as an Area of Special

Amenity and as being a gateway to the more upland areas classified as Areas of Outstanding Natural

Beauty. The Inspector recognises that the visual impact of the proposal is an important consideration

however notes that the designation of the area as such does not necessarily preclude development if it

can be demonstrated that such would have an acceptable visual impact”.

Furthermore, the Inspector recognises that site coverage of the proposed development is likely to entail

a significant visual change to the character of the landscape. Notwithstanding such, the Inspector

acknowledges that the solar panels themselves are low profile structures and the proposal has allowed

for new hedgerow boundaries. Having regard to this, the Inspector notes that” given the localised

nature of the visual impact, which would not be unacceptable in the context of the adjoining local road

and from existing dwellings in the vicinity, I would consider that the overall visual impact of the

development would be acceptable”.

6.2.2.2 Wexford County Council Planning Reference: 20140392 – An Bord Pleanala Reference:

PL26.244351

In relation to middle range visual impacts, the Inspector concurs "with the applicant's broad contention

that there would be visual containment by hedgerows and topography in middle range views”. It was

further outlined by the Inspector that “there would be some potential views from R734, but fleeting

and oblique, and not necessarily unpleasant, given the orientation”. (Emphasis added)


LVIA and Glint & Glare Planning and Environmental Report


The Inspector set out that the Landscape and Visual Impact Assessment (LVIA) submitted with the

proposal “asserts that the form would be difficult to discern beyond 5km. Having viewed a number of

existing solar forms in the UK, this is consistent with my experience”.

6.2.2.3 Cork County Council Planning Reference: 14/06644 – An Bord Pleanala Reference: PL

04.244539

The Inspector was of the view that while the appearance of the array in the landscape “will certainly

be a departure from anything which exists at present”, it was pointed out that there were a number of

activities/uses which can have a visual impact (temporary or longer term) such as the ploughing of a

field, laying of clear plastic on fields to increase soil temperatures, glasshouses, & Polytunnels.

Similarly, the Inspector considers that the proposed fencing “will not have any impact on the visual

amenities of the area”.

6.2.3 Methodology

The LVIA methodology is based on the approach set out in in the Guidelines for Landscape and Visual

Impact Assessment 3rd Edition1 (Landscape Institute and Institute of Environmental Management and

Assessment) and Department of the Environment and Local Government, Landscape and Landscape

Assessment. (June 2000)2, whilst also considering other best practice guidance and using professional

judgement.

The LVIA considers the potential impact of the Development and the resulting landscape and visual

effects, which have been assessed separately within the LVIA.

The methodology of the LVIA is outlined within Section 2 of Appendix F: Landscape and Visual

Impact Assessment and takes the following approach:

- Firstly, identify and evaluate separately the existing landscape and visual baseline within a 5km

study zone. This includes undertaking an initial desktop study of the Landscape Character

Areas, Designations, Scenic Views or Routes Views within the Roscommon County Council

Development Plan 2014-2020 and potential viewpoints to be considered. The later fieldwork

helps to correlate this data within the existing landscape of the study zone and to carry out the

assessments.

- Determine the landscape and visual receptors with potential to be affected by the proposed

Development and their sensitivity to the proposed changes resulting from the Development;

- Assess the interaction of the proposed Development with the landscape receptors and establish

a judgement of the ‘degree of effects’ the proposed Development will have upon each receptor;

- Assess the interaction of the proposed Development with the visual receptors and establish a

judgement of the ‘degree of effects’ the proposed Development will have upon each receptor;

and

- Determine any necessary mitigation measures in order to help reduce the potential effects and

the expected residual effects.

1 Landscape Institute and Institute of Environmental Management and Assessment (2013, 3rd edition) Guidelines for Landscape and Visual

Impact Assessment, Routledge, London.

2 Department of the Environment and Local Government (2000) Landscape and Landscape Assessment. Available at:

http://www.environ.ie/search/archived/current?query=landscape




6.2.4 Zone of Theoretical Visibility

The Zone of Theoretical Visibility (“ZTV”) (see Figures 4a and 4b, Appendix F) was produced as a

‘bare earth scenario’ to show the potential visibility of the proposed Development across the local area,

out to 5km from the Application Site boundary. The ZTV was calculated using Digital Terrain Modelling

(“DTM”) sourced from digital data derived from Ordnance Survey Ireland, with the viewer height set at

2m high. For the purpose of producing the ZTV and in carrying out the assessment, the maximum

height of the solar arrays has been assumed to be 2.805m above ground level.

The ZTV does not account for any elements in the landscape such as trees, hedgerows, walls or

buildings that may help screen views, nor account for the influences of the weather upon any views. It

therefore represents a ‘worst case scenario’, nonetheless the ZTV is a useful computer generated tool

for determining the potential visibility of the proposed development and initial selection of viewpoints

for the visual assessment.

6.2.5 Landscape Impact

The Application Site falls within the Roscommon Town & Hinterland LCA 32 whose main characteristics

include the rich cultural heritage of Roscommon town together with its low lying dry grassland and

some bogland, forestry and drumlin features.

The potential effects upon the characteristics of the rural landscape of the Roscommon Town &

Hinterland LCA 32 will be greatest within the immediate vicinity, where there is a localised change from

the current rough pasture land use to one of renewable energy generation with pasture.

The nature of this Development when operational will allow for most of the existing land cover to retain

an agricultural use through the low intensity grazing of the lands found between and beneath the solar

arrays.

The design layout has ensured that the Development elements have been largely fitted around the

existing field hedgerow boundaries, which are an important characteristics of the Roscommon Town &

Hinterland LCA 32.

Overall, the Development will have a localised Moderate to Moderate/Minor adverse effect on the

characteristics of the Roscommon Town & Hinterland LCA 32 within the immediate surroundings of the

site reducing to Minor Adverse effects across the wider LCA. The Development will have no notable

effects on any neighbouring LCAs.

The proposed Development will result in some minor losses of trees and hedgerows and disturbance to

the grounds during the construction phase in order to facilitate the project. The loss of vegetation will

be compensated by providing replacement planting consisting of a mix of native species hedgerows

and screen planting mixes along field boundaries of Field 1-5 and through parts of Fields 1,2 and 3

along the Application Site’s southern edge. The retained field boundary hedgerows will be strengthened

by infilling up any gaps with similar species. The mitigating planting measures will help retain a high

degree of enclosure to the Application Site.

The layout of the various structures have been sited so that they are respectful of the existing

topographic levels within the proposed Application Site. Only minor earthworks and grading will occur

around the bases of the supporting buildings and access tracks. The proposed Development will have

a Moderate to Moderate/Minor adverse effect on the Application Site during its operation.

The landscape setting of the three Historic Gardens and Designed Landscapes and three Architectural

Conservation Areas which fall within the ZTV coverage will remain unaffected by the proposed




Development. Thus the proposed Development will have No indirect effects upon these various

landscape designations.

6.2.6 Visual Impact

During the field visit an assessment of ten representative viewpoints located across the study zone was

undertaken. A number of these viewpoints are representative of the nearest residential receptors found

located alongside the L7122 (L1811) Road opposite or near to Application Site’s southern boundary.

Other viewpoints considered includes those from roads and public amenity areas located further away.

There will be some limited partial ground level views from a small number of residences, as shown by

Viewpoint 1, 2, 3 and Viewpoint 4. Here views will be from the fronts or sides of these properties looking

onto parts of the Application Site, with the Development within the nearer Fields 1, 2 and 3 being most

prevalent. Two properties considered from Viewpoint 2 will also have upper floor views looking over

the roadside hedgerow onto the Development. The proposed mitigation planting to be implemented

along the Application Site’s southern edge is intended to help reduce the potential visibility of the

Development’s Structures from these nearest receptors.

Road users will experience some brief passing views through minor gaps in the roadside hedgerows

near to these residents. No receptors will be able to experience views of all of the Development as the

retained field hedgerows and varying topography help to break up the visibility of the new structures.

Potential views from other receptors found across the wider study zone were assessed including other

rural and urban residents, road users, cyclists on way marked route and the County Council’s Scenic

Views. However, the Development will not be visible from these receptors as the relatively low scale of

the proposed structures together with fluctuations in the local topography and high degree of screening

provided by intervening hedgerows, trees or buildings all help to fully screen any views looking in the

direction of the proposed site.

The majority of receptors will experience No Change to their existing views as a result of the

Development. A small number of rural residents and local minor road users on the L7122 (L1811)

immediately south of the Application Site will experience between Major/Moderate and Minor

adverse visual effects depending on the extent and duration of such views. These initial predicted visual

effects at Year 0 will reduce as the mitigation planting fills out over time helping to further screen any

inward views of the Development.

There are no other known existing or proposed solar farms or similar developments in the 5km study

zone which could have the potential for any notable cumulative landscape or visual effects.

6.2.7 Mitigation

The landscaping mitigation measures will have beneficial effects in the form of improved grassland

cover and strengthening of hedgerows which will help improve the rural character and biodiversity of

the Application Site and surroundings. The improved field boundaries can be retained after the

decommissioning of the development’s structures. In order to provide continuous screening of the

Development field hedgerows will where possible be retained and infilled as required.

The boundaries edges along the southern ends of Field 3 and 2 will need to be adjusted to facilitate

the required access sightlines. In order to reduce any potential views due to this breach in the field

boundary hedgerows additional native species planting in the form of hedgerows, trees and screen

planting on a low berm will be added to the edges of both fields. Infill planting of the retained roadside

hedgerows and additional screen planting within Field 1 will further help reduce any potential inwards

views from the nearest receptors to the south and southeast. Other mitigation measures include

appropriate siting and the use of suitable colours and finishes to the associated infrastructure, which

will limit the visibility from any receptors, helping them to fit within the landscape.




All mitigation measures are indicated on the Ecology and Landscape Mitigation Plan, (see

Appendix G of the Planning and Environmental Report).

6.2.8 Conclusion

The overall design of the Development has carefully considered its setting within the confines of the

agricultural lands and wider rural landscape to ensure it limits its effects upon landscape and visual

receptors. Due to the outlying nature of the proposed site and relative low heights of the various

proposed structures will help ensure that the majority of receptors found within the immediate and

wider landscape of the study zone will have no views of the Development.

Mitigation measures have been proposed to help reduce any potential effects including reducing the

development’s visibility from the nearest sensitive residential receptors. At the end of the Development’s

lifespan the predicted effects are reversible as the lands can be returned to an agricultural use similar

to their current state with relative ease.

6.3 GLINT AND GLARE

6.3.1 Introduction

A glint and glare study is concerned with the potential hazard and nuisance effects of glint and glare in

relation to ground-based receptors that include the occupants of surrounding dwellings as well as road

users. In their “Technical Guidance for Evaluating Selected Solar Technologies on Airports” the Federal

Aviation Administration (“FAA”) have defined the terms ‘Glint’ and ‘Glare’ as meaning;

- Glint – “A momentary flash of bright light”

- Glare – “A continuous source of bright light”

Glint and glare are essentially the unwanted reflection of sunlight from reflective surfaces.


The conclusions drawn from the following An Bord Pleanala appeals in relation to glint and glare are

noted:

6.3.2.1 Wicklow County Council Planning Reference: 16/176 – An Bord Pleanala Planning


With regard to Glint and Glare, the Inspector makes reference to An Bord Pleanala Ref. PL26.244539

report where it was stated that “the issue of glare is not particularly relevant to solar panels”. Despite

the Inspector recognising that “the applicant has provided no information regarding potential impact of

the development in regards to glint”, the Inspector states that “I would note that vegetation would

mitigate against any glint impacts and in general” and ”Overall I would consider that given the low

potential occurrence of glint from the proposed development and the nature of the landscape that the

proposed development would not have any significant impacts on the surrounding area in relation to

glint and glare”.

6.3.2.2 Cork County Council Planning Reference: 15/5424 – An Bord Pleanala Reference:

PL04.245862

The Inspector makes reference to appeal ref. PL04.244539 report where it was stated that the” issue

of glare is not particularly relevant to solar panels and this was the same conclusion reached in the

submitted Planning and Environmental Report in the current appeal before the Board”.




In terms of glint, it is noted that the applicant submitted a Planning and Environmental Report which

outlined that the proposed solar panels are very dark in colour and they are designed to absorb light

rather than reflect light. In this regard, the Inspector considers that” given the low potential occurrence

of glint from the proposed development as outlined by the applicant, the sparsely populated local area

and the nature of the landscape that the proposed development will not have any significant impacts

on the surrounding area in relation to glint and glare”.

6.3.2.3 Wexford County Council Planning Reference: 20140392 – An Bord Pleanala Reference:

PL26.244351

The Inspector acknowledges that the issue of glint and glare was a 'new issue' for the Irish Planning

System. Essentially the Inspector outlined that “when the sun is low in the sky - morning and evening

-, light can reflect from the surface of panels to ground based observers to the west and east,

respectively. As with the issues of noise and shadow flicker for wind turbines, the potential effects on

receptors can be modelled at planning stage, and indeed is often done as a matter of course in the UK,

on foot of their guidelines”.

The Inspector was of the view that the (glint and glare) study submitted identified potential impacts at

two properties and that “screening and planting is cited as being a mitigation measures” which was

considered “sufficient to mitigate against impacts on ground floor and ground level receptors, in my

opinion”.

6.3.2.4 Cork County Council Planning Reference: 14/06644 – An Bord Pleanala Reference: PL

04.244539

The Inspectors notes that the “issue of glare is not particularly relevant to solar pv arrays – glint being

more likely. Glint only occurs when the sun is shining”. The Inspector stated that “I would be satisfied

that the proposed development will not have any significant impact on the surrounding area in relation

to glint and glare”.

6.3.3 Methodology

The glint and glare study uses a multi-step process of elimination to determine which receptors have

the potential to experience the effects of glint and glare. It then examines, using a computer generated

geometric model, the times of the year and the times of the day such effects could occur. This is based

on the relative angles between the sun, the panels and the receptor throughout the year.

A 500m survey area around the solar panel areas was considered adequate for the assessment of

ground based receptors. Geometric analysis was conducted at 24 dwellings within this study area along

with 13 receptor points along the L7122 (L1811).

6.3.4 Summary of Results

Following an initial assessment, rail receptors were scoped out as assets that will not be impacted upon

from the proposed Development. The assessment concluded that:

- Out of 24 residential receptors within the 500m study area, solar reflections were only theoretically

possible at 22 of these and the worst case predicted impact was deemed to be low at 13 receptors

and none at 11.

- The impact on the residential receptors was limited to between 4 and 7 minutes per day, between

the times of 18:39 and 18:59 in the evening for the receptors to the East and between the times

of 06:06 and 06:44 in the morning for the receptors to the West. It was also limited to between

the months of March and September. It is noted that these results do not take into account existing

or proposed vegetation which will serve to limit views. Predicted impacts therefore present a worst

case scenario.




- Photographic evidence was used to identify receptors which were likely to be impacted from the

Development. When investigated further it was identified that the potential for impacts was

significantly reduced at all of the receptors due to intervening vegetation and buildings, which are

anticipated to block the line of sight to the solar farm.

- The maximum observed angle between the sun and the solar farm reflection at the dwelling

receptors is 18.4 degrees which suggests the suns direct beam will be the dominant issue and

should mask the solar farms reflections at these properties.

- Impacts on the L7122 (L1811), N63 and N61 were considered. The impact on the L7122 (L1811)

is considered to be low or none depending on which part of the road the receptor is located. It was

concluded that the impact on both the national roads would be none.

- The closest aerodrome to the application site is the Abbeyshrule Aerodrome which is a small airport

some 34km from the proposed Development. This is outwith the airports safeguarded zone and

there will be no impact from the Development upon operations at this airport.

6.3.5 Conclusion

The effects of glint and glare and its impact on local receptors has been analysed in detail and although

there is anticipated to be some impacts on local dwellings, these are anticipated to be extremely limited

and therefore of low significance.

Creevyquin Solar Farm Section 7 Planning and Environmental Report Archaeology, Architectural & Cultural Heritage Assessment


7.0 ARCHAEOLOGY, ARCHITECTURAL & CULTURAL HERITAGE ASSESSMENT

7.1 OVERVIEW

Neo Environmental has been appointed by Gaelectric to assess the impact on the archaeological

heritage on and within the environs of the proposed site for the development of a proposed solar farm

with associated infrastructure (“the Development”) on lands at Creevyquin, Roscommon, Co

Roscommon (“the Application Site”).

This section summarises (and should be read in conjunction with) the Appendix I: Archaeology,

Architectural Heritage and Cultural Heritage Assessment.

7.2 METHODOLOGY

A desk based assessment was undertaken to identify the baseline heritage resources within study zones

of 5km and 2km around the Application Site boundary. Heritage assets considered in this stage included

National Monuments in State Care (“NMSC”), Historic Gardens and Designed Landscapes (“HGDL”), the

Record of Protected Structures (“RPS”) and the Record of Monuments and Places (“RMP”). Further

methods such as map regression analysis, a field walkover survey and aerial photography analysis were

used to identify further archaeological potential and unrecorded assets.

Direct and indirect impacts were evaluated for heritage assets identified in the desk-based assessment.

This involved an appraisal of the Application Site for its archaeological potential as well as the production

of a Zone of Theoretical Visibility (“ZTV”) to identify which assets may be visually impacted as a result

of the proposed Development.

The National Monuments Service internal guidance for solar farm developments released in November

2016 (“the NMS Guidance”) which outlines the considerations and requirements for archaeology with

respect to solar farms has been used and referred to in the assessment.

7.3 BASELINE HERITAGE AND ARCHAEOLOGY

There are no heritage or archaeological assets within the RMP, RPS or NIAH that are within the

Application Site boundary. The closest heritage asset to the proposed works is the Hilltop Enclosure

(NA13) c. 100m to the west. The Zone of Notification (ZTV) of this site borders the Application Site

boundary, but neither the monument nor the Zone of Notification are within the Application Site itself.

A site visit identified the possible remains of an enclosure within Field 4, while the ditch and bank

remains of two or three early 19th century field boundaries were located within Field 5. Nothing of

archaeological interest was identified within Fields 1 – 3 and there were no identifiable remains of the

19th century building or holding pen depicted in Field 2 on the 25 Inch OSI Map.

Within the ZTV there is a total of one NMSC and three HGDLs located within the 5km study zone

(Appendix I – Figure 1), while 30 sites within the RMP and two sites within the RPS/NIAH are located

within the Zone of Theoretical Visibility in the 2km study zone (Appendix I – Figure 2). However, no

ACAs or World Heritage Sites were identified in their respective study zones.

Map regression analysis revealed only minor changes to the field boundaries and land use; specifically

former field boundaries which were removed in the 19th and 20th centuries. Although it is outside the

Application Site, it should be noted that the hilltop enclosure adjacent to the west of Fields 3 and 4

underwent considerable disturbance in the period between the 6 inch OSI map (1829 – 1841) and the

25 inch OSI map (1897 – 1913). This disturbance includes the truncation and removal of the

southwestern extent of the enclosure by an additional field boundary, as well as the construction of

another new field boundary that runs through the western side of the enclosure in a southwest to

Section 7 Creevyquin Solar Farm Archaeology, Architectural & Cultural Heritage Assessment Planning and Environmental Report


northeast orientation. No further disturbance appears to have occurred subsequently, but the interior

of the enclosure has clearly been utilised as an area of grazing.

7.4 ASSESSMENT OF IMPACTS

7.4.1 Direct Impacts

The main potential direct impacts during the construction phase would result from groundworks

required by the proposal, including the excavation of cable trenches, driving of piles to support the solar

arrays and topsoil stripping required for on-site access tracks and assembly areas. In addition,

foundations are required for any inverter/transformer units and on-site sub-stations.

Only potential unrecorded archaeological assets were identified within the Application Site during the

site visit. However, the proximity of the site to the nearby hilltop enclosure indicates that there is some

potential for related sub-surface archaeological remains within the Application Site boundary. Map

regression analysis did not highlight anything further of archaeological interest. The assessment

anticipates the direct impacts to be low, before appropriate mitigation is introduced.

7.4.2 Indirect Impacts

The setting and potential visual impact upon each of the designated heritage assets have been assessed

through a desk based assessment and site visit. The ZTV was overlain onto the heritage assets map in

order to identify those which have a greater potential to be visually impacted by the proposed

Development. The ZTV does not account for intervening hedgerows, trees or built structures, which will

considerably limit the intervisibility between the building/monument and the proposed Development.

There was one NMSC identified within the 5km study zone that is within the ZTV of the proposed

Development. This was Roscommon Castle (NA01) for which a negligible indirect impact was assessed.

There were three HGDLs identified within the 5km study zone that were within the ZTV of the proposed

Development, including; Carrowroe (NA02), Roxborough House (NA04) and Mote Park (NA06). A

negligible indirect impact was assessed for all three of these assets. There were two protected

structures within the RPS that are within the 2km study zone and the ZTV of the proposed Development;

Carrowroe House (NA11) and St. Coman’s Roman Catholic Cemetery (NA12). A negligible impact was

assessed for both buildings. There were 30 sites identified in the RMP that are within the 2km study

zone and the ZTV of the proposed Development. Most of these assets were considered to be too far

away or of insufficient significance to be sensitive to the proposed Development.

Of the relevant assets, a low impact was assessed for the Creevyquin Hilltop Enclosure (NA13) in the

absence of mitigation and the Creevyquin-Killeenboy (NA15), while a negligible impact was assessed

for Cloonybeirne Rath (NA14) and the Carrowroe Village features (NA24 – 31).

There were no ACAs or World Heritage Sites identified in their respective study zones. Roscommon ACA

is partially within the ZTV but is located just outside the 2km study zone. As such it will not be visually

impacted by the proposed Development.

7.5 MITIGATION MEASURES

There is limited scope to mitigate against the direct impacts from piling upon potential sub-surface

archaeology as no foundation trenches will be required, limiting archaeological visibility. Where areas

of topsoil stripping or deeper excavation is required (e.g. assembly areas, access tracks, cable routes)

mitigation of these impacts is possible through an archaeological watching brief.

Due to the possible enclosure feature or relict field boundary identified during the site visit, there is

some potential for encountering below-ground archaeology within the Application Site during the

construction phase. This potential has been assessed as low, but some degree of mitigation is

Creevyquin Solar Farm Section 7 Planning and Environmental Report Archaeology, Architectural & Cultural Heritage Assessment


recommended. The design layout of the proposed Development has completely avoided the potential

enclosure/relict field boundary feature so that construction works will not directly impact upon it. As

such, pre-development archaeological mitigation is not anticipated to be necessary. However,

archaeological monitoring is recommended for any groundworks (limited to construction of access

tracks, cable trenches, substation, inverter / transformer stations and the temporary construction

compound) conducted during the construction phase in order to preserve by record any sub-surface

remains encountered. Any further work would be at the discretion of the NMS and Roscommon County

Council. Post mitigation residual effects have been assessed as negligible.

Indirect impacts upon the surrounding heritage assets have been assessed as negligible for all assets

other than the Creevyquin Hilltop Enclosure (NA13) and the Creevyquin-Killeenboy Rath (NA15), which

were both assessed as low. Therefore, no specific mitigation is considered to be required for the

reduction of any visual impacts. However, Appendix F: Landscape and Visual Impact Assessment

(“LVIA”) recommends that the hedgerow boundary between the Creevyquin Hilltop Enclosure (NA13)

and the Application Site be maintained to ensure that visual impacts are kept minimal. This

recommendation has been adopted in the LVIA, which states:

“The growth of the new structure planting along with existing hedgerows and trees will be maintained

by cutting on a rotational basis to help thicken the field boundaries and limit views into the site” (Section

8.2).

7.6 COMPLIANCE WITH THE NMS GUIDANCE

Compliance with the NMS Guidance requirements is demonstrated by the following:

- (a) Examination of the relevant documentary sources (SMR, RMP etc.): Sections 3.3 - 3.4 of

Appendix I quantifies and discusses the assets present within the RMP, RPS and NIAH within

appropriate study zones.

- (b) Report on field inspection of the entire site: Sections 3.8 – 3.10 of Appendix I documents

both the desktop and the site visit of the Application Site.

- (c) Quantification of the ground-disturbance impact on the ‘site’ identifying in particular areas of

serious ground disturbance (e.g., trenching, sub-stations) but also quantifying the cumulative level

of ground disturbance from piles to support solar arrays and assessing possible impact from driving

machinery over land while inserting piles or subsequently removing them and ways in which such

machine disturbance will be reduced or eliminated”: The quantification of ground disturbance and

the potential direct impacts resulting from this have been discussed and assessed within Sections

4.26 - 4.40. Due to the limited archaeological evidence identified within the area of the proposed

construction works, direct impacts are anticipated to be low, as per the conclusion of the report.

- (d) Visual impact assessment: A comprehensive visual impact assessment, including National

Monuments in State Care and World Heritage Sites / candidate World Heritage Sites, was

undertaken in Sections 4.1 – 4.25 of Appendix I.

7.7 CONCLUSION

The proposed solar farm will not substantially impact any known heritage assets. However,

archaeological monitoring during the construction phase is recommended due to the proximity of the

Application Site to the hilltop enclosure to its west. It is unlikely that any unrecorded sub-surface

archaeological remains will be encountered and with the implementation of mitigation measures, the

proposed Development will not substantially impact upon any potential sub-surface archaeology.

The proposed Development will therefore not significantly affect any assets or their settings and

complies with the relevant policies and guidance, including the recently introduced National Monuments

Section 7 Creevyquin Solar Farm Archaeology, Architectural & Cultural Heritage Assessment Planning and Environmental Report


Service Guidance Document. As the Roscommon County Development Plan largely defers to national

policy, policies within documents such as the Planning and Development Act 2000 and National

Monuments Act 1930 have been considered for this purpose.


Planning and Environmental Report Traffic and Transport Assessment


8.0 TRAFFIC AND TRANSPORT ASSESSMENT

8.1 OVERVIEW

Neo Environmental were appointed by Gaelectric to assess the traffic and transport impact for the

development of a proposed solar farm with associated infrastructure (“the Development”) on lands at

Creevyquin, Roscommon, Co. Roscommon (“the Application Site”).

The trip generation from the operational phase of the proposed Development will not reach the numbers

to justify a full Traffic and Transport Assessment (as per the National Road Authority (NRA) Guidance),

defined as traffic to and from the development exceeding 10% of the traffic flow on the adjoining road,

or 5% where congestion exists or the location is sensitive.

This section summarises (and should be read in conjunction with) Appendix J: Construction Traffic

Management Plan (“CTMP”).

8.1.1 Pre Planning Advice

Telephone and email consultation (see Appendix J) was undertaken with Jennifer Collins, Planning

Officer for Roscommon County Council. It was confirmed that the design of the visibility splay at the

new site entrance should be 90m x 3.0m, in line with the County Development Plan. Further

correspondence was conducted in related to the local road which runs parallel to the southern boundary

of the Application Site. On the OSi mapping and signage this road is referred to as the L1811, however

this has been recently changed to the L7122. Jennifer Collins requested that we refer to this road as

the L7122 (L1811).

In addition to this, a pre-application meeting took place on the 3rd of August and John Moclair (Area

Engineer) brought up the following points in relation to access:

- A new access point would be acceptable;

- A new access which avoided being directly opposite houses would be preferable;

- Will there be wheel washing facilities and where will the runoff be directed; and

- A query regarding construction times and traffic volumes, with a focus on HGV’s.

The traffic and transport assessment fully considers and details the level of traffic generated and

frequency of trips at both the construction and operation phases.

8.2 TRAFFIC AND TRANSPORT ASSESSMENT

8.2.1 Proposed Site Access

The Application Site will be accessed via the L7122 (L1811) on its southern boundary. It is intended

that all traffic generated by the proposed Development will use a new access point off the L7122

(L1811). The speed limit on Local roads is generally 80km/h and signs were visible whilst on site to

confirm this. The location of the site access is shown on Figure 3 and Figure 4 of Appendix J.

An existing access point on the L7122 (L1811) at the Application Sites south eastern corner was

considered, however to achieve the required visibility would have required more remedial work than

the chosen access point and would also have meant the intensification of an existing access which is

directly in front of a dwelling. It was observed that vehicles travelling on the L7122 (L1811) near the

proposed Development access reach speeds up to the statutory speed limit and the width of the road

at the proposed site entrance is 3.7m wide. This section of road does not contain any lane markings or

carriageway edge markings and is not lit by public lighting. There are no pedestrian facilities along this


Traffic and Transport Assessment Planning and Environmental Report


section of road and the surface of the carriageway near the site entrance is in good condition. The

length of the L7122 (L1811) from the N63 to the new site access is mostly the same width as at site

entrance. There are also numerous passing places along this stretch of road. In line with the local

development plan, sightlines of 90m x 3.0m will be developed at the proposed site entrance (see Figure

3 of Appendix J). This arrangement is considered to be appropriate for this type of rural access off of

a local road and has been confirmed in writing by the Planning Officer (see Appendix B). Figure 3

shows the 90m x 3.0m visibility splay and highlights that there is a requirement for vegetation trimming

and tree removal in order to facilitate this. Therefore, pre-construction ecological surveys - similar to

those discussed in more detail in the Ecological Impact Assessment (Appendix C of the Planning and

Environment Report) for other areas of the Application Site where this is proposed - will be completed

pre-construction. It is noted that all lands required for the 90m x 3.0m visibility splay access are under

the control of the Applicant. Existing over ground and underground services at the site entrance will be

diverted as necessary to facilitate site entrance works and to provide visibility splays. Trimming of

vegetation in the public road verge will be carried out to maximise visibility at the junction. Any land

that needs trimming is within the control of the Applicant.

8.2.2 Haul Routes to Site for Construction Traffic

The proposed delivery route has been identified by considering the ability of the route to physically

accommodate the required vehicles, as well as the sensitivity of the route to potential disruption that

may be caused by the movements. As there are no abnormal loads associated with the Development,

only access from the closest motorway will be considered on the assumption that the motorway is large

enough to handle any standard load manoeuvres.

The delivery vehicles will travel along the M6/N6 which is located to the south of the proposed

Application Site. Vehicles will exit the M6/N6, just north of Athlone, and travel along the N61 in a south

to north direction for approximately 28km. After which, vehicles will exit the N61 at the roundabout in

Roscommon and take the 3rd exit onto the N63. They will follow the N63 for approximately 1.4km and

take a right turn onto the L7122 (L1811) and follow this local road until the reach the new site entrance.

The following enabling works will be required in order to facilitate the movement of HGVs to the

Application Site.

- Existing telegraph pole to be relocated onto in verge behind sightlines in order to help achieve

required visibility at the site entrance (see Figure 3 of Appendix J).

- Hedgerow trimming/realignment will be required also in order to facilitate the required visibility at

the site entrance (see Figure 3 of Appendix J).

8.2.3 Construction Traffic Management

The construction period for the proposed Development is anticipated to occur over a 12-16 week period.

During this period there will be a combination of HGVs for the component deliveries and cars/vans for

construction staff. HGV movements are expected to be most intense throughout the first 6 – 8 weeks

of construction, tailing off towards the final weeks. Car/van movements are expected to be constant

throughout.

8.2.4 Construction Parking

It is forecast that there will be a maximum of 23 staff on site at any one time during the construction

period, although this will vary subject to the overall programme of works. It is likely that there will be

a degree of vehicle sharing by staff and, therefore, it is anticipated that there will be significantly less

than 23 staff vehicles per day arriving on site (estimated maximum at 10-12 per day at peak

construction periods). Labour vehicle sharing will be actively encouraged to reduce vehicular

movements. On entrance/exit to/from the site, worker’s vehicles will report directly to the area of hard


Planning and Environmental Report Traffic and Transport Assessment


standing at the temporary site construction compound where there will be sufficient space for parking

and turning. Site opening hours will be before the peak traffic period, and closing time will be after

night time peak hours, and should therefore, not cause disruption at the peak periods on entrance/exit

of the site.

8.2.5 Operational Period

The operational phase of the solar farm is anticipated to have negligible trip generation potential with

approximately 5-10 Light Goods Vehicles (LGVs) expected every year, with additional visits required to

attend to remedial issues when necessary. The operational access point will use the same entrance to

the site as during the construction period.

8.2.6 Decommissioning Period

The number of HGVs required for the decommissioning period will be slightly higher than the

construction phase due to the materials not being as neatly packed as when shipped from factory

conditions. However whilst the construction phase had a total of 356 movements, the decommissioning

phase will have a total of around 392 movements. This increase is not considered to be significant.

8.2.7 Mitigation

The impact of the proposed Development has been identified as being temporary in nature and

associated with short construction and decommissioning stages only. It is still important that any impact

is minimised as far as possible and, in light of this, the following mitigation measures have been

considered:

- Traffic movements will be limited to 08:00 - 18:00 Monday to Friday and 08:00 - 16:00 on

Saturdays, unless otherwise agreed in writing with Roscommon County Council. Further, deliveries

will be scheduled to avoid peak times around the morning and evening peak hours. This will avoid

HGV traffic arriving during the morning peak hour creating conflicting with local residents on their

commute/school run. Construction personnel will be encourage to car-pool, or to travel to site in

minibuses;

- During the construction phase, clear construction warning signs will be placed along the L7122

(L1811) and at the site access, advising the general public as to the presence of the construction

site. The site entry point will also be appropriately signed. Access to the construction site will be

controlled by on site personnel and all visitors will be asked to sign in and out of the site by security

/ site personnel. Security gates will be sufficiently set back from the road, so that vehicles entering

the site will stop well clear of the public road. Site visitors will all receive a suitable Health and

Safety site induction, and Personal Protective Equipment (“PPE”) will be worn.

To control, prevent and minimise dirt on the access route and emissions of dust and other airborne

contaminants during the construction works, the following mitigation measures will also be

implemented:

- Damping down site roads to minimise dust emissions;

- Wheel wash watering equipment will be available and used on-site, as required, to prevent the

transfer of dirt and stones onto the public highway. All drivers will be required to check their vehicle

is free of dirt, stones and dust prior to departing the solar farm;

- Any dust generating activities will be avoided or minimised, wherever practical, during windy

conditions;

- Any soil stockpiles will be covered when left for extended periods of time;

- Drivers will adopt driving practices that minimise dust generation; and


Traffic and Transport Assessment Planning and Environmental Report


- Loads in and out of site will be covered when required.

- Once construction of the Development is completed all Port-a-Cabins, machinery and equipment

will be removed and hardstanding excavated. The area will be re-graded with the stockpiled topsoil

to a natural profile and allowed to regenerate from the seed bank within the topsoil.

8.3 CONCLUSION

The CTMP submitted as Appendix J sets out the overall framework for managing the movement of

construction and delivery traffic to and from the proposed Development, as well as considering the type

of traffic which will be generated. The traffic assessment of the operational and decommissioning

phases are also considered.

The Construction Traffic Management Plan conforms to the policies and objectives of the Roscommon

County Council Development Plan 2014-20, and the Design Manual for Roads and Bridges published by

the NRA.


Planning and Environmental Report Hydrology, Geology, FRA and OCEMP


9.0 HYDROLOGY, GEOLOGY AND FLOOD RISK ASSESSMENT AND OUTLINE CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN

9.1 OVERVIEW

Neo Environmental has been appointed by Gaelectric to assess the geological, hydrological and

hydrogeological impact of a proposed solar farm with associated infrastructure (“the Development”) on

lands at Martinstown, Athboy, Co Meath (“the Application Site”). As part of this assessment, a Flood

Risk Assessment (“FRA”) has been completed, and an Outline Construction Environmental Management

Plan (“OCEMP”) has been drafted by Woodrow Sustainable Solutions.

This section summarises (and should be read in conjunction with) Appendix K: Hydrology, Geology

and Flood Risk Assessment and Appendix E: Outline Construction Environmental

Management Plan.

9.2 BASELINE

Table 9.1 below outlined the hydrology, geology and hydrogeology baseline of the Application Site.

Table 9.1: Baseline Conditions

Asset Description Importance

Topography

(Figure 4 of

Appendix K)

According to the topographical survey the highest point

of the Application Site is 58m AOD which lies to the

eastern section of Field 1. The lowest point of the

Application Site is 50m AOD which lies adjacent to the

northern section of Field 5.

N/A

Geology

(Figure 5,

Appendix K)

The proposed Application Site is underlain by three

types of bedrock geology, including: Ballysteen

Formation, Waulsortian Limestones and Argillaceous

Limestones.

GSI does not identify any karst features within the

Application Site or the surrounding area, or any bedrock

outcrops within the Application Site itself. No bedrock

outcrops or karst were identified during the site

walkover.

There are no Bedrock Boreholes located within the

proposed Application Site, or within close proximity.

Nothing further in this respect was identified during the

site walkover.

The nearest active quarry is Castlemine Quarry located

approximately 6.1km west-northwest of the Application

Site.

According to the GSI (2016) on-line database, there are

presently no records of geo-hazards such as landslides

within or in close proximity to the Application Site.

The GSI on-line mapping was reviewed to identify sites

of geological heritage within the Application Site and

surrounding area. There is no evidence of any site in

the immediate area of the Application Site which could

be considered suitable for protection.

Low


Hydrology, Geology, FRA and OCEMP Planning and Environmental Report



Soil (Figure

6, Appendix

K)

There are two different types of subsoil distributed

across the proposed Application Site, including:

TLs - Till derived chiefly from limestone; and

Rck – Bedrock outcrop or subcrop.

According to the Wallingford Procedure Winter Rain

Acceptance Potential (WRAP) map, the soil classification

for the Application Site is Class 1, which is indicative of

“well drained permeable sandy or loamy soils and

shallower analogues over highly permeable limestone,

chalk, sandstone or related drifts”. This soil class has an

SPR of 0.1 and should provide good opportunity for

infiltration.

High

Hydrology

(Figure 7,

Appendix K)

The Application Site lies within the Shannon Upper

Water Framework Directive Catchment Area and within

the Hind River sub-catchment SC_010. The main

tributaries of the Upper Shannon are the Rivers Suck,

Inny and Brosna.

The closest watercourse to the Application Site is the

Creevyquin Stream which lies to the west. This stream

flows in a southern direction before meeting with the

River Jiggy on the edge of Roscommon. The River Jiggy

meets with the River Hind some 2.5km further south.

The site walkover survey identified the presence of one

drainage ditch within the Application Site running

parallel to the southern boundary where most of the

Application Sites overland flow will discharge to. This

drainage ditch discharges into the Creevyquin stream to

the west. Some of the overland flow will discharge to

the north of the Application Site where there are a series

of connected drainage ditches just outside the Norther

Boundary. Again, these drainage ditches will discharge

into the Creevyquin stream to the west of the

Application Site.

Further investigation of the EPA and Myplan1 map

viewer as well as the catchment areas from the OPW

online maps confirmed that the field drains all lead to

the Creevyquin Stream to the west of the proposed

Application Site.

Low

Flood Risk

According to this map there are areas identified as

Pluvial Flood Zone A located within the southern and

north western areas of the Application Site boundary.

Flood Zone A has a high probability of flooding, greater

than 1% AEP or 1 in 100. It is noted that the

Development electrical infrastructure has been located

outside of these areas.

N/A

1 Myplan Map Viewer. Available at http://www.myplan.ie/viewer/





Hydrogeology

(Figure 10

and Figure

11, Appendix

K)

According to the GSI map, the proposed Application Site

lies within the Curraghroe Groundwater Body (“GWB”)

which is described as being moderately productive in

local zones.

The underlying bedrock aquifer at the proposed

Application Site is considered by GSI to be Locally

Important, covering an area of 461.46km2.

According to the GSI map the groundwater vulnerability

across the proposed Application Site is considered to a

combination of ‘Extreme’, ‘High’ and ‘Rock at or near the

surface’. The majority of the Application Site is classified

as ‘high’ vulnerability.

A review of the GSI wells database revealed that there

is a borehole located within close proximity to the

Application Site. The buffer area extends within the

Application Site area, however, the locational accuracy

of the borehole location is to 1km. During the site

walkover there were no signs of any borehole within the

application site.

Medium

9.3 ASSESSMENT OF IMPACTS

9.3.1 Construction Phase

The construction phase of the proposed Development will occur over a 12 to 16 week period and will

include the installation of the security fence, access tracks, construction compound, foundations for the

associated buildings and the installation of the solar panels.

Potential impacts during the construction phase in relation to soil, geology and hydrogeology include:

- Compaction;

- Erosion;

- Excavation; and

- Contamination from spillages and leaks.

The potential for compaction of the soil is considered to be Short Term with a Small Adverse magnitude

of impact. Therefore, the potential impact is considered to be Moderate / Slight. Mitigation measures

will be adopted throughout the construction phase to reduce the occurrence of compaction. The

potential for impacts associated with the excavation of the soil is considered to be Short Term with a

Small Adverse magnitude of impact. Therefore, the potential impact is considered to be Moderate /

Slight. Mitigation measures will be adopted throughout the construction phase to reduce the potential

impacts.

The potential impact upon hydrogeology during the construction phase is considered to be Short Term.

The magnitude of impact is considered to be Small Adverse therefore significance is considered to be

Slight prior to the implementation of mitigation measures.

Potential impacts during the construction phase in relation to hydrology include the following:

- Contamination of surface water from chemical stored and used onsite;




- Modification to surface water runoff;

- Impediments to flow; and

- Erosion and sedimentation.

In relation to the contamination of local watercourses, the potential impact is considered to be Short

Term with a Small Adverse magnitude of change. Therefore, prior to the implementation of mitigation

measures the potential impact is considered to be Imperceptible.

9.3.2 Operational Phase

The operational phase of the proposed Development will be 30 years. During this time, the proposed

Development will be generally unmanned and will be monitored remotely. Occasional access will be

required for maintenance of the infrastructure and ground beneath and around the solar panels.

Potential impacts upon geology, soils and hydrogeology during the operational phase are considered to

be limited. There will only be occasional visits to the site for maintenance, whereby staff will access the

site utilising 4X4 vehicles. Accidental leakages from these vehicles could occur along the access tracks,

however this is considered to be insignificant.

In terms of potential hydrology impacts, there will be no wastewater discharges into the receiving

environment during the operational phase. During operation of the solar farm, maintenance of the

panels will be infrequent and will only require light machinery. Thus, the infiltration rate of the

underlying ground is unlikely to be impacted by the proposed Development.

Due to the limited activities onsite during the operational phase of the proposed Development it is

considered that the potential duration of impact is Long Term, with a Negligible magnitude. Therefore

the potential impact upon geology and hydrology is considered to be Imperceptible.

9.3.3 Decommissioning Phase

Decommissioning effects are expected to mirror those of the construction phase.

9.4 FLOOD RISK ASSESSMENT

Flood planning policy for Ireland is set out by the Department of Environment, Heritage and Local

Government in ‘The Planning System and Flood Risk Management Guidelines for Planning Authorities2’

(“the FRM Guidelines”) document.

In accordance with the FRM Guidelines, a Stage 1 Flood Risk Identification has been undertaken. The

aim of which is to identify whether there may be any flooding or surface water management issues

relating to the proposed Application Site.

This section provides a summary on the findings of the Stage 1 FRA which is contained within Appendix

K: Hydrology, Geology and Flood Risk Assessment.

9.4.1 Phase 1 Flood Risk Identification

The Preliminary Flood Risk Assessment Map (Map reference 2019/MAP/288/A) provides a broad

overview of the source and significance of all types of flood risk. According to this map there are areas

identified as Pluvial Flood Zone A located within the southern and north western areas of the Application

Site boundary. Flood Zone A has a high probability of flooding, greater than 1% AEP or 1 in 100. It is

2 Department of Environment, Heritage and Local Government (2009) The Planning System and Flood Risk Management. Available at: http://www.opw.ie/media/Planning%20System%20and%20Flood%20Risk%20Management%20Guidelines.pdf




noted that the electrical infrastructure associated with the Development has been located outside of

these areas.

The National Flood Hazard Mapping does not identify any flood events within close proximity to the

proposed Application Site. The closest flood event to the proposed Application Site lies approximately

1.4km to the west, which is in relation to a recurring flood event at the N63 within Roscommon town,

from the River Jiggy. From reviewing floodmaps.ie there was no evidence of flooding at the Application

Site from any significant watercourse.

9.4.2 Conclusions

No further stages of Flood Risk Assessment are required.

9.5 DRAINAGE IMPACT ASSESSMENT

The Planning System and Flood Risk Management Guidelines3 recognises the potential for Sustainable

Drainage Systems (“SuDs”) to alleviate flood risk in Ireland.

Surface water arising from a developed site should, as far as is practicable, be managed to mimic the

surface water flows arising from the site prior to the proposed Development, while reducing the flood

risk to the site itself and elsewhere

9.5.1 Proposed Drainage Strategy

Any existing onsite drainage ditches or features will be retained in their existing state, and will continue

to intercept overland flows from the site.

While it has been argued above that the proposed Development will not result in a material increase in

surface water run-off flow rates, it is proposed to construct a swale within the Application Site. The

swale has been located on one of the steeper sections of the Application Site to help protect against

soil erosion as well as providing attenuation storage.

Due to the presence of the new berms near the southern boundary of the Application Site a filter drain

has been recommended for conveyancing reasons along the longest berm so that existing surface water

flows are not altered. Although this will also provide some attenuation storage, the primary function is

to direct overland flow to the existing discharge points and avoid ponding on the northern side of the

berm. The two smaller berms are small enough so that overland flow should easily flow around and

not effect existing overland flow routes.

The swale will slow down surface water flows, help to filter pollutants and then discharge into the

existing field drain in exceedance events.

The proposed swales will be of an overall length of approximately 105m, with a base width of 300mm,

a 300mm design depth, 150mm freeboard and a maximum side slope of 1 in 3.

The proposed swale will provide a total storage volume of approximately 37.80m3. This is greater than

the volume of additional run-off generated as a result of the impermeable buildings (13.43m3). It is

therefore considered that this adequately mitigates the increase in flow rate as a result of the minor

increase in impermeable area and provides a degree of improvement.

The swale will be constructed before construction of the solar farm commences and planted with

covering vegetation to protect against soil erosion. The swale will be maintained throughout the design

3 Department of the Environment, Heritage and Local Government (2009) The Planning System and Flood Risk Management Guidelines for Planning Authorities. Available at: http://www.environ.ie/sites/default/files/migrated-files/en/Publications/DevelopmentandHousing/Planning/FileDownLoad%2C21709%2Cen.pdf




life of the Development, generally in accordance with the recommendations in the appropriate

guidance.

Additional drainage measures to be implements onsite include the following:

- Solar Panels: current grass cover is to be retained or reinstated adjacent to and under panels in

order to maximise bio-retention. No further formalised drainage proposed.

- Access Tracks: Access tracks are to be unpaved and constructed from local stone. Temporary

swales or similar shall be utilised to collect run-off from access tracks with discharge to ground

through percolation areas. Where swales are utilised, check dams formed from gravels and other

excavated material shall be placed in the swale at frequent intervals. The indicative road

construction details are highlighted in drawing number “Gaelectric_Solar_008.”

- Transformer / Inverter Stations (and similar hardstands): the scale of these type of

structures is unlikely to warrant a formalised drainage system. Runoff from this infrastructure and

any associated hard standing should be directed to a percolation areas for discharge to ground.

- Stream maintenance: Siting of green space for landscaping adjacent to mapped drains and

watercourses on the Application Site will ensure ongoing access for maintenance. The site layout

of the proposed Development is such to ensure that no built development, fixed barrier or other

impediment to access is placed within 10-15m of mapped drains and watercourses on site in order

to comply with fisheries best practise guidelines.

9.6 MITIGATION

9.6.1 Geology, Hydrology & Hydrogeology

Although the potential geological, hydrological and hydrogeological impacts identified as a result of the

proposed Development are not considered to be significant, the following mitigation measures will be

implemented as best practice. These mitigation measures have also been outlined within Table 9.2

below and are detailed within the accompanying Outline Construction Environmental

Management Plan (“OCEMP”), contained within Appendix E.

The OCEMP framework is intended to form the basis of a future CEMP, including detailed action plans

and method statements once contractor(s) have been appointed. The main environmental impacts

which have been identified and covered by the OCEMP are as follows:

- Water pollution – Silt/Sediment from construction works;

- Water pollution – Cement and concrete;

- Water pollution from the storage and use of fuels, oils & other chemicals; and

- Soil Compaction resulting in soil erosion and increased sediment loading.

Table 9.2: Mitigation Measures

Measure Description

Waste Management

Storage of Fuels and

Chemicals

As per Best Practice Guidance (BPGCS005) , all fuels, oils and chemicals on site will

have a secondary containment system of 110% capacity and be located more than

20m from any watercourse (i.e. outside of the water course buffer).




Measure Description

Spill kits will be on site and, for ease of access, located in the site office. Contingency

plans will be in place for dealing with a spillage should a spillage occur.

Refuelling During construction, fuel and oil deliveries shall take place within the designated

refuelling area within the Temporary Construction Compound only.

Excavation and

Earthworks

All excavation and earthworks, including for the levelling of the spoil head in Field 4,

will be carried out in accordance with BS6031:2009 Code of Practice for Earthworks4.

Soil handling, extraction and management will be undertaken with regard to best

practice guidelines such as Guidance on the Waste Management (Management of

Waste from the Extractive Industries) Regulations 20125.

Concrete

Concrete will not be allowed to enter watercourses under any circumstances, and

drainage from excavations in which concrete is being poured will not be discharged

directly into existing watercourses without appropriate treatment and consent from the

relevant authority.

Wheel washing equipment to be used near the site entrance, and where necessary

lined washout pits will be utilised.

There will be no use of wet concrete within 20m of the drainage ditch along the

southern site boundary.

Pollution Prevention

Protection Measures

Protection measures will include the following:

- Plant and equipment will be stored on dedicated hard standing within the

construction compound. This will minimise the risk of pollution caused by

leakages occurring out of hours. Drip trays will be used where

appropriate.

- All plant and equipment will utilise biodegradable hydraulic oil.

- Spill kits will be readily available to all personnel. The spill kits will be of

an appropriate size and type for the materials held on site.

- Diesel fuel will be stored in a bunded diesel bowser which will be located

within a fenced off area in the construction compound.

- Refuelling and maintenance of vehicles and plant will take place in

designated areas of hardstanding.

- All other chemicals will be stored within a storage contained with an

accompanying COSHH Datasheet.

- Wastewater from the temporary staff toilets and washing facilities will be

discharged to sealed containment systems, and disposed via licensed

contractors.

Early seeding of embankments near watercourses would be undertaken to reduce the

potential for sediment run-off.

4 British Standards Institute (BSI), 2009. BS 6031:2009 Code of Practice for Earthworks

5 Environmental Protection Agency (EPA) 2012. Guidance on the Waste Management (Management of Waste from the Extractive Industries) Regulations 2012. Available at www.epa.ie




Measure Description

Flood Risk

Drainage

The Development has been designed in order to reduce the possibility of additional

flood risk impacting the surrounding area. Some of these design features include:

- The proposed access roads will be formed using permeable materials

such as open graded stone or reinforced grass so as to avoid creating

impermeable areas across the site.

- 105m of swales have been proposed which will be sown with the

appropriate seed mix upon construction.

- A filter drain has been proposed to divert any overland flow around the

largest proposed berm to avoid ponding as well as to keep the existing

overland flow routes.


Planning and Environmental Report Noise Impact Assessment


10.0 NOISE IMPACT ASSESSMENT

10.1 OVERVIEW

Neo Environmental Ltd has been appointed by Gaelectric Renewable Energy Developments Ltd (“the

Applicant”) to provide a Noise Impact Assessment (“NIA”) of a proposed solar farm with associated

infrastructure (“the Development”) on lands at Creevyquin, Roscommon, Co Roscommon (“the

Application Site”).

This section summarises (and should be read in conjunction with) Appendix B: Noise Impact

Assessment.

10.2 CONSTRUCTION NOISE

Construction due to its nature is a temporary activity and thus any impacts will be short term. All

construction works will be carried out during the day-time period. Construction plant will be throttled

down or turned off when not in productive use. Accordingly, all construction traffic to be used on site

should have effective well-maintained silencers. Operators of all mobile equipment will be instructed to

avoid unnecessary revving of machinery. Where possible the contractor will be instructed to use the

least noisy equipment.

As all manufacturing will be done off site, there will be no welding or metal cutting machinery used to

construct the pre-fabricated solar racking. This will be transported in complete units and fastened to

the foundations.

Potential noise impact will be controlled in accordance with all relevant British Standards Codes of

practices such as: BS 5228-1: 1997 “Noise Control on Construction and Open Sites - Part 1”; BS

5228:2009 and Al:2014 “Code of practice for noise and vibration control on construction and open sites”

and BS 8233:2014 “Guidance on Sound Reduction and Noise Insulation for Buildings”.

Decommissioning noise conditions will be similar to the construction phase.

10.3 OPERATIONAL NOISE

In the operational phase of the project, the solar panels will operate completely silently. Whilst the

solar panels themselves are not noise producing, the inverter / transformer stations emit only a very

low level of noise. The majority of the external noise is created by the air conditioning unit needed to

keep the inverter cool. The noise output under full load is less than 65dBA within 10m and the inverters

do not generate any noise emissions outside of daylight hours. This level would be significantly reduced

by both the housing used to surround the inverters / transformer stations and distances to the nearest

receptors. As noise generated correlates with solar load, no noise would be produced at night.

This infrastructure is positioned at least 150m away from residential receptors to ensure no impact on

residential amenity.


The conclusions drawn from following An Bord Pleanala appeals in relation to noise are noted:

Wicklow County Council Planning Reference: 16/176 – An Bord Pleanala Planning


The Inspector acknowledges that minimal noise levels may be generated during the operational phase

with the main noise impact produced at construction phase, and was of the opinion that ”the

construction phase is a temporary phase and that the operational phase of the proposal will generate


Noise Impact Assessment Planning and Environmental Report


no noise impact” and that “noise levels likely to be generated would be within acceptable limits and

that a standard condition requiring compliance with recommended EPA noise emission limit could be

applied”. The Inspector also notes that” given the temporary nature of construction and appropriate

construction management restrictions including noise limits and hours of construction the proposal

would be acceptable in to noise impact”.

Cork County Council Planning Reference: 15/5424 – An Bord Pleanala Reference:

PL04.245862

The Inspector notes that “I would consider that the construction noise, subject to compliance

conditions, from the proposed development would be acceptable……Overall I would consider that

operational noise from the proposed development is not a significant issue.”

Wexford County Council Planning Reference: 20140392 – An Bord Pleanala Reference:

PL26.244351

With regards to noise, the Inspector outlines that “the applicant's response that the unwavering

consensus among design consultants and contractors is that this solar panels or mounting structures

do not cause noise. I can find no credible evidence that suggests that noise is an issue with solar farms.

While there might be some electrical hum from the plant buildings, these ore located on the western

fringes of the site, away from any sensitive receptors”.

10.3.2 Operational Noise Impact Assessment

The objectives of the operation noise impact assessment were to identify and describe any likely

significant noise effects on key receptors during the operational phase of the proposed Development.

In order to assess the potential noise impacts of the proposed Development, the current baseline

characteristics of the Application Site and the surrounding area were identified as well as the predicted

impacts of the proposed Development.

A simulation of noise associated with the proposed Development was provided by SoundPlan modelling

software to predict noise levels for the purpose of undertaking a ISO9613-21 assessment.

An impact assessment was then conducted comparing the predicted effects of the operation stage of

the development against the World Health Organisations Guideline Values.

For both day time and night time periods the impact has been deemed as either low (rating level is less

than the WHO Guideline Value but more than 10dB below the WHO Guideline Value) or negligible

(rating level is more than 10dB below the WHO Guideline Value) at all of the NSRs in both the external

and internal amenity areas. The Development is therefore in line with the Development Management

Guidelines and Standards contained within the Roscommon County Development Plan (2014-2020).

1 International Standards Organisation (1996) Acoustics – Attenuation of sound during propagation outdoors, Dec 1996


Planning and Environmental Report Suggested Conditions


11.0 SUGGESTED CONDITIONS

11.1 INTRODUCTION

The Applicant proposes that the following conditions be included on the decision notice for the

Development when issued by Roscommon County Council.

11.2 CONDITIONS

11.2.1 Site Layout and Design

As mentioned in Section 4: Site Location and Project Description, the final detailed design of the

Development may have some minor variations to the infrastructure outlined in the submitted planning

application. An over-riding principle will be that any minor differences will be kept to a minimum, and

only implemented where absolutely necessary. This approach follows best practice in the UK and

Northern Ireland. Any amendments will generally be due to the specific requirements of the site,

discovered via ground investigation works (for example), or final design drawings prepared by the

Engineer, Procure, Construct (“EPC”) contractor. Geotechnical surveys and detailed design will inform

the location of site tracks, inverter and transformer stations, substation, temporary storage compound,

fencing, CCTV cameras and panels / racks, but at all times they will be located within 15m micrositing

distance of that shown on the submitted site layout plans.

To ensure Roscommon County Council approval of the final detail design and layout, Gaelectric

proposes the following pre-commencement condition:

“No development shall commence until a detailed design plan showing the final position and

layout of the panels, electrical equipment and associated infrastructure is submitted to and

approved in writing by Roscommon County Council. The development shall thereafter be

constructed in accordance with the approved plans”.

11.2.2 Construction

The civil works themselves are non-invasive, reflecting the temporary nature of the proposed

Development. In this regard a detailed Construction Management Plan (“CMP”) will be submitted prior

to commencement. In the event of a grant of permission Gaelectric proposes the inclusion of a condition

with the following wording suggested:

“Prior to commencement of the development, a Construction Management Plan shall be

submitted to the planning authority for written agreement. This plan shall provide details of

intended construction practice for the development.”

11.2.3 Decommissioning

The proposed Development is temporary and will have an operational lifetime of 30 years. At the end

of its operation all infrastructure will be decommissioned, dismantled and removed from the site. In

order to condition the decommissioning of the Development, the Applicant suggests the following

wording:

“Prior to commencement of the development, a detailed restoration plan, providing for removal

of foundations and access roads to a specific timescale shall be submitted to the planning

authority for written agreement. The site shall be restored in accordance with the said

programme and all decommissioned structures shall be removed within six months of

decommissioning”.


Planning and Environmental Report Conclusions


12.0 CONCLUSIONS

12.1 INTRODUCTION

Gaelectric Renewable Energy Developments Ltd (“the Applicant”) is seeking to apply for planning

permission to develop a solar photovoltaic (“solar PV”) energy generation project on lands at

Creevyquin, Roscommon, Co. Roscommon (“the Application Site”).

The proposed Development is to consist of a 10 year planning permission for the development of a

solar photovoltaic (“PV”) energy development to include: a single storey electrical substation building,

electrical inverter and transformer stations, solar PV panels mounted on metal frames, new access

tracks, underground cabling, perimeter fencing with infrared CCTV and access gates, temporary

construction compound, spare parts container, weather station, a new access point and all ancillary

infrastructure and associated works within a total site area of up to 34 acres.

The scale, location and layout of the proposed Development have all been carefully considered in order

to comply with the plans, policies and guidelines discussed in Section 2: Planning Policy Context.

Although the proposed Development does not trigger the requirement for an Environmental Impact

Assessment, this report addresses key environmental considerations including Landscape and Visual

assessment, Ecology, Glint & Glare, Archaeology, Traffic/Transportation and Water/Drainage.

12.2 CONCLUDING COMMENTS

At present, there is no specific national guidance for commercial solar farms in Ireland. Notwithstanding

this, the principle of solar photovoltaic is supported in the context of wider established policy relating

to the promotion and development of renewable energy. The West Regional Planning Guidelines 2010-

2022 and the Roscommon County Development Plan 2014-2020 (“the Development Plan”) are all

considered to be supportive of the development of renewable energy technology, particularly in the

context of reducing the carbon emissions of the country and meeting renewable energy production

targets.

In particular, the Development Plan outlines solar energy objectives which will support the proposed

Development, such as policies 4.53 which seeks to encourage the development of renewable energy

sources such as solar. Objective 4.57 is also supportive of solar energy development stating an aim

to “encourage the development of renewable energy sources in an appropriate and sustainable

manner”.

The Appropriate Assessment Screening Report (Appendix D) has identified the particular types of

effect that have potential for adverse impact on the integrity of a number of Natura 2000 sites. The

screening has acknowledged that, on the basis of best scientific knowledge, there will be no significant

effects on any Natura 2000 sites as a result of this Development, taking account of the sites’

conservation objectives, either individually or in combination with other plans or projects.

The unmitigated potential impacts caused by the proposed Development on the ecological environment

range are identified in the Ecological Impact Assessment (Appendix C). Mitigation measures have

been proposed to address the identified impacts. These measures include restrictions of tree and hedge

felling/cutting to outside of the breeding bird season, planting hedgerows and screening belts of native

tree species to replace lost habitat and to enhance existing treelines and hedgerows, bringing the

hedgerows in the site under an ecologically sensitive management regime, planting a species rich

grassland, planting a wildflower margin, creating a drainage buffer zone and the creation of a swale.

The landscaping mitigation measures will have beneficial effects in the form of improved grassland and

hedgerows which will help strengthen the rural character and biodiversity


Conclusions Planning and Environmental Report


Based on the landscape and visual impact judgements provided throughout the LVIA (Appendix F),

the proposed Development at Creevyquin is not considered to give rise to any significant residual

impacts. Overall, the operational Development will have a much localised Moderate adverse effect on

the characteristics of a small proportion of the Roscommon Town and Hinterland LCA. This effect will

be reduced to Minor Adverse effects when considered across the wider extent of this LCA. The majority

of receptors will experience No Change to their existing views as a result of the Development. A small

number of rural residents and local minor road users on the L7122 (L1811) immediately south of the

Application Site will experience between Major/Moderate and Minor adverse visual effects depending

on the extent and duration of such views. These initial predicted visual effects at Year 0 will reduce as

the mitigation planting fills out over time helping to further screen any inward views of the Development.

With regards to glint and glare (Appendix H), it is not considered that there will be any significant

nuisance or hazard effects generated from glint and glare as a result of the proposed Development.

The significance of effects will not be greater than Low at residential properties.

The Noise Impact Assessment Report (Appendix B) concludes that for both day time and night time

periods the impact has been deemed as either low or negligible at all of the noise sensitive receptors

in both the external and internal amenity areas.

The archaeological assessment (Appendix I) concludes that the proposed Development will not

substantially impact any known heritage assets. However, archaeological monitoring during the

construction phase is recommended due to the proximity of the Application Site to the hilltop enclosure

to its west. It is unlikely that any unrecorded sub-surface archaeological remains will be encountered

and with the implementation of mitigation measures, the proposed Development will not substantially

impact upon any potential sub-surface archaeology.

The proposed Development will therefore not significantly affect any assets or their settings and

complies with the relevant policies and guidance, including the recently introduced National Monuments

Service Guidance Document which is addressed in Section 7.6 of Appendix I.

Given the construction phase is expected to last for a relatively short time period and will generate a

low level of additional trips on the surrounding road network, the proposed Development is not expected

to result in any significant impacts on the existing road conditions. When completed and operational,

the only access to the site will be from maintenance vehicles etc., which will generate a very low number

of trips. Increased volumes of traffic will be generated by the proposed Development during the short

construction period only. However the overall volumes of traffic generated by the proposed

Development during the construction period are considered to be low and will not impact adversely on

the existing road network.

A geological, hydrological and flood risk assessment (Appendix K) was completed and no significant

constraints to development were identified. The Flood Risk Assessment has demonstrated that the

Development proposal can be developed in this location without increasing flood risk away from the

Application Site. Specific measures will be implemented which will result in a net reduction in surface

water flow to the sensitive receptors in the locality and therefore the proposed Development is

considered to be acceptable in planning policy terms. As part of the Flood Risk Assessment process, the

conclusion of this ‘Stage 1 Flood Risk Identification’ is that the Application Site is not at risk of flooding

(fluvial, pluvial or groundwater) and the proposed Development will not result in any significant change

in risk or flooding regime.

The proposed Development includes significant benefits in addition to the generation of energy from a

renewable source. These include social benefits associated with the potential use of the site as an

educational resource; economic benefits relating to job creation during both construction and operation;


Planning and Environmental Report Conclusions


and environmental / landscape benefits including biodiversity improvements and proposed planting

measures.

In summary, it is considered that the scheme as proposed accords fully with local, regional and national

planning guidelines. Having regard to the limited scale of the proposed Development, the pattern of

development in the vicinity, and the landscape proposals, we respectfully ask Roscommon County

Council to agree that the proposed Development is in accordance with the proper planning and

sustainable development of the area.