s t s tipperary renewable energy strategy 2014 a tipperary... · communications, energy and natural...

March 2014

SOUTH TIPPERARY COUNTY COUNCIL & THE TIPPERARY ENERGY AGENCY

SOUTH TIPPERARY RENEWABLE ENERGY STRATEGY 2014

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Project Steering Group Clare Lee, South Tipperary County Council Paul Kenny, Tipperary Energy Agency Sonja Reidy, South Tipperary County Council George Mason, Strategic Policy Committee Sub-Committee for Energy Richard Long, Strategic Policy Committee Sub-Committee for Energy Richard Auler, Strategic Policy Committee Sub-Committee for Energy Strategic Policy Committee for Planning & Economic Development Cllr Joe Brennan, Chairman Cllr Micheal Murphy, Cllr Liam Ahearne, Cllr Micheál Anglim, Cllr Sean McCarthy, Cllr Billy Shoer, Cllr Teresa Ryan, Cllr Kieran Burke, Cllr Anna Tuohy-Halligan, Cllr Eoghan Lawrence John O’Shaughnessy, Donal O’Halloran Moya Breen Ger Kennedy South Tipperary County Council Cllr Liam Ahearne Cllr Micheál Anglim Cllr Seanie Lonergan Cllr Marie Murphy Cllr Jack Crowe Cllr Sean McCarthy (Mayor) Cllr Tom Wood Cllr Louise McLoughlin Cllr Tom Acheson - Leas Cathaoirleach Cllr Siobhán Ambrose Cllr Pat English Cllr Billy Shoer Cllr Richie Molloy Cllr Michael Murphy Cllr Darren Ryan Cllr Joe Brennan Cllr John Fahey Cllr Jimmy O'Brien – Cathaoirleach Cllr Eddie O'Meara Cllr Sylvia Cooney Sheehan Cllr John Crosse Cllr Joe Donovan Cllr Michael Fitzgerald Cllr Mary Hanna Hourigan Cllr Denis Leahy Cllr Micheal Cleere

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Executive Summary South Tipperary County Council is committed to the sustainable development of South Tipperary and its energy resources in a manner that protects the environment, supports energy self-sufficiency and provides employment in the county. In June 2013 the Sustainable Energy Authority of Ireland published their ‘Methodology for Local Authority Renewable Energy Strategies’, the purpose of which was to provide a framework for the development of renewable energy in Ireland and to ensure a consistent approach at local authority level. This Renewable Energy Strategy has been prepared by South Tipperary County Council and the Tipperary Energy Agency in line with the SEAI methodology and provides a framework for the sustainable development of renewable energy in the county. The total consumption of fuel in the county across the main economic sectors of agriculture, commerce, residential, transport and industry is growing by an average of 1.4% annually. Energy in the county is currently primarily supplied by fossil fuel sources, including gas and oil, with energy from renewable sources accounting for only approximately 3% of total fuel consumed.

The ‘National Renewable Energy Action Plan’ produced by the Department of Communications, Energy and Natural Resources has set out nationally binding targets for renewable energy consumption that will ensure that by 2020, 16% of the total national consumption of energy will be from renewable energy sources. In order to support this target the Government has identified key goals to be achieved that will support and stimulate the renewable energy industry.

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South Tipperary has the potential to produce renewable energy from its upland wind resources and from biomass sourced in its strong agricultural and forestry industries, energy may also be produced from the county inland water resources and to a lesser extent from solar and geothermal energy resources. Energy can be produced from these resources at the large, medium and small scales. This Renewable Energy Strategy has examined the resources of the county and the key facilitators, including resources and infrastructure and constraints, including the environment to the development of renewable energy and has identified a sustainable way forward for the development of renewable energy resources. Consideration has also been given to the potential for direct returns to the local economy and community through employment and community benefits. This Strategy is mindful of the need to support the development of renewable energy whilst at the same time ensuring that new development does not result in an adverse impact on the assets of South Tipperary including its water quality, heritage, landscape, infrastructure and communities. In this sense South Tipperary County Council supports the development of renewable energy where a balance can be achieved with the need to produce energy from renewable resources and the need to protect the environmental resources of the county. This Strategy was endorsed by the Strategic Policy Committee for Planning and Economic Development on the 11th February 2014 and thereafter was endorsed by South Tipperary County Council on the 3rd March 2014. The recommendations of this Strategy will go forward to inform the development of a statutory planning policy for renewable energy development with the support and consensus of the all stakeholders in the area through the County Development Plan process.

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Table of Contents

Glossary of Terms .............................................................................................................................. 4

1.0 What is a Renewable Energy Strategy? .................................................................................. 7

1.1 What are Renewable Energy Resources? ............................................................................ 7

1.2 Why prepare a RES? ......................................................................................................... 11

1.3 Stakeholders .................................................................................................................... 12

1.4 Format of this RES ............................................................................................................ 14

2.0 Renewable Energy Policy Overview & Legislative Context .................................................... 18

2.1 European Policy ............................................................................................................... 18

2.1.1 Directive 2009/28/EC - Promotion of the Use of Energy from Renewable Sources .... 18

2.1.2 EU Targets for non Emissions Trading Scheme (ETS) Sector emissions ...................... 18

2.2 National Policy ................................................................................................................. 19

2.2.1 Strategy for Renewable Energy 2012-2020, Department of Communications, Energy and Natural Resources .............................................................................................. 19

2.2.2 The National Renewable Energy Action Plan (NREAP) 2010 ...................................... 20

2.2.2 The National Climate Change Strategy (2007-2012) .................................................. 20

2.2.3 National Energy Efficiency Action Plan: Maximising Ireland’s Energy Efficiency, 2013- 2020 (NEEAP) ........................................................................................................... 21

2.2.4 Bioenergy Action Plan for Ireland (2007-2020) .......................................................... 21

2.2.5 National Spatial Strategy 2002 (NSS) ......................................................................... 21

2.2.6 The Planning and Development (Strategic Infrastructure) Act 2006 .......................... 21

2.2.7 The Planning and Development (Amendment) Act 2010 ........................................... 22

2.2.8 Part L of the Second Schedule of the Building Regulations 1997 – 2008 .................... 22

2.2.9 Wind Energy Guidelines and update ......................................................................... 22

2.3 Regional and Local Policy ................................................................................................. 22

2.3.1 South East Regional Planning Guidelines................................................................... 22

2.3.2 South East Regional Authority Bio-Energy Implementation Plan ............................... 24

2.3.3 South Tipperary County Development Plan 2009-2015 ............................................. 24

2.4 Related Renewable Energy Initiatives ............................................................................... 24

South Tipperary Renewable Energy Strategy 2014

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2.5 Strategic Environmental Assessment and Habitats Directive Assessment (Appropriate Assessment) ..................................................................................................................... 25

3.0 County Renewable Energy Resources, current Planning Policy & Barriers ............................. 28

3.1 Wind ................................................................................................................................ 28

3.2 Bioenergy ......................................................................................................................... 31

3.3 Hydro Power .................................................................................................................... 33

3.4 Solar ................................................................................................................................ 35

3.5 Geothermal ...................................................................................................................... 36

4.0 Energy Balance & Renewable Potential Assessment ............................................................. 37

4.1 County Energy Demand (baseline and 2020) .................................................................... 37

4.2 Renewable Energy Production .......................................................................................... 38

4.3 Renewable Energy Potential of the county ....................................................................... 40

5.0 Assessment of Supports & Constraints for Renewable Energy Production ............................ 45

5.1 Infrastructure ........................................................................................................................ 45

5.1.1 Electricity ................................................................................................................. 45

5.1.2 Gas ........................................................................................................................... 47

5.1.3 Transportation ......................................................................................................... 47

5.1.4 Services and Utilities................................................................................................. 48

5.1.5 Telecommunications and Aviation ............................................................................ 48

5.2 Environmental and other constraints ............................................................................... 48

5.2.1 Natural Heritage ....................................................................................................... 48

5.2.2 Landscape and Visual Amenity .................................................................................. 49

5.2.3 Archaeological and Architectural .............................................................................. 49

6.0 Renewable Energy Benefits & Supports................................................................................ 50

6.1 Economic benefits of RE production ................................................................................. 50

6.2 Renewable Energy Types and Technologies ...................................................................... 50

6.3 Renewable Energy Support Schemes ................................................................................ 51

6.4 Renewable Energy Projects and Local Community Involvement ....................................... 52

6.4.1 Planning and Development Exemptions .................................................................... 52

6.4.2 Planning Application and Community Consultation ................................................... 53


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6.4.3 Strategic Infrastructure............................................................................................. 53

6.4.4 Community Gain and Renewable Energy Development ............................................ 54

7.0 County Renewable Energy Strategy ...................................................................................... 56

7.1 Vision for Growth ............................................................................................................. 56

7.2 Renewable Energy Strategic Targets ................................................................................. 57

7.3 Policy Development ......................................................................................................... 59

7.3.1 Protection of the Environment ................................................................................. 59

7.3.2 Wind ........................................................................................................................ 60

7.3.3 Biomass .................................................................................................................... 61

7.3.4 Hydropower ............................................................................................................. 62

7.3.5 Solar ......................................................................................................................... 63

7.3.6 Geo- thermal ............................................................................................................ 63

7.4 Monitoring ....................................................................................................................... 64

Appendicies

Appendix 1: Strategy for Renewable Energy 2012-2020 – Strategic Goals. ....................................... 66

Appendix 2: List of Persons who made Pre-Draft submissions .......................................................... 72

Appendix 3: Map of Wind Energy Production Areas from County Wind Energy Strategy .................. 75

Appendix 4: Environmental report and Appropriate Assessment…………………………………………………….78


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Glossary of Terms

AA Appropriate Assessment (AA) - An assessment carried out under Article 6(3) of the Habitats Directive of the implications of a plan or project, either individually or in combination with other plans and projects, on a Natura 2000 site in view of the site’s conservation objectives.

Biomass Biological Material produced from organic materials, either directly

from plants or indirectly from industrial, commercial, domestic or agricultural products, may be used as a source of fuel.

CHP Combined Heat and Power is the simultaneous on-site generation of

usable heat and electricity. District-heating A system for distributing heat generated in a centralised location for

residential and commercial heating requirements. Energy is usually produced in CHP.

EirGrid EirGrid is the independent electricity Transmission System Operator in

Ireland and the Market Operator of the wholesale electricity trading system.

Fossil Fuels Fuel in form of hydrocarbons, primarily coal, fuel oil or natural gas,

formed from the remains of dead plants and animals. Geothermal Energy Geothermal energy refers to heat energy stored in the ground. Heat is

supplied to the ground from two sources namely the hot core of the planet and the sun. It can be classified as either 'deep' or 'shallow' depending on the depths involved.

Greenhouse Gas Greenhouse gases are gases that trap heat in the atmosphere, the

four most important are -carbon dioxide, methane, nitrous oxide, and fluorinated gases.

GRIDLINK A new 400 kV overhead power line linking Leinster and Munster to be

constructed by Eirgrid. The power line will link will connect Knockraha in Cork with Great Island in Wexford to Dunstown near Naas, Kildare.

GRID25 EirGrid's plan to develop and upgrade the electricity transmission

network up to 2025. It involves extensive work throughout the country which includes building 800km of new power lines and upgrading 2,000 km of existing lines which will double the size the electricity Grid.


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Head height Hydropower potential is a function of the hydraulic head height and the rate of fluid flow. The head is the energy per unit weight (or unit mass) of water, the higher the head height the more power may be generated.

Insolation Insolation is the solar radiation that reaches the earth's surface. It is

measured by the amount of solar energy received per square centimetre per minute.

Miscanthus Miscanthus, or elephant grass is a perennial grass native to

subtropical and tropical regions of Africa and southern Asia and is one of a new generation of renewable crops that can be converted into renewable energy by being burned in biomass power stations.

Micro-Generation The small-scale generation of heat and electricity by individuals, small

businesses and communities to meet their own needs, as an alternative to or to supplement grid-connected power.

Natura 2000 sites A network of European sites comprising Special Areas of Conservation

and Special Protection Areas (including candidate and proposed sites), selected for the conservation of Habitats in line with the Birds and Habitats Directives.

Photovoltaic Photovoltaic systems (PV system) use solar panels to convert sunlight

into electricity. PHES Pumped Hydro Energy Storage is a method of storing electrical energy

as potential energy by pumping water from a reservoir or lake to another reservoir at a higher elevation and storing it for use in generating electricity when required.

REFIT REFIT stands for 'Renewable Energy Feed in Tariff' and is the primary

means through which electricity from renewable sources is supported in Ireland.

RES Renewable Energy Strategy. Run-of-the-river A type of hydro-electric generation whereby little or no water storage

is provided, energy is harnessed by diverting river flow through turbines before returning water back to the river.

SEA The process as set out by the SEA Directive by which environmental

considerations are systematically assessed and fully integrated into the preparation of Plans and Programmes and prior to their final adoption.

https://en.wikipedia.org/wiki/Head_(hydraulic)�

https://en.wikipedia.org/wiki/Rate_of_fluid_flow�


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Shadow Flicker The blades of a wind turbine may cast a shadow and the rotation of the blades causes the shadow to flick on and off. This effect lasts only for a short period and happens only in certain specific combined circumstances.

SEAI The Sustainable Energy Authority of Ireland (SEAI), formerly the Irish

Energy Centre was set up by the government in 2002 as Ireland's national energy authority.

TEA Not for profit consultancy established in 1998 as a partnership

between the South and North Tipperary Local Authorities and the Tipperary Institute. The aim of the TEA is to promote renewable energy, energy efficiency and the rational use of energy, to improve the quality of the environment and to contribute to sustainable development.


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1.0 What is a Renewable Energy Strategy? South Tipperary County Council and the Tipperary Energy Agency (TEA)1 recognise the need for Ireland to exploit its renewable energy resources in order to achieve national targets for reductions in fossil fuel dependency and greenhouse gas emissions. It is the function of this Renewable Energy Strategy (RES) to set out a framework under which the renewable energy potential of county Tipperary can be identified and realised in a sustainable manner whilst preserving the cultural, natural and built environment of the county. This RES will support and inform the review of the South Tipperary County Development Plan and in due course will inform the preparation of an amalgamated County Development Plan for Tipperary2

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South Tipperary County Council wishes to actively facilitate and drive the development of renewable energy within its functional area, through the guidance of Ireland’s national energy authority - the Sustainable Energy Authority of Ireland (SEAI). This RES has been prepared in conjunction with the input and participation of the SEAI, the TEA and the key stakeholders involved in the renewable energy sector. It has also been prepared having consideration to comments and input received from the general public and anyone with an interest in the long-term sustainable development of the county. The format and content of this RES has been derived from the SEAI’s ‘Methodology for Local Authority Renewable Energy Strategies’, March 2013.

1.1 What are Renewable Energy Resources?

Renewable energy comes from energy resources that are continuously replenished through the cycles of nature. Unlike fossil fuels, their supply will never become exhausted. The main sources of renewable energy are: the sun (solar energy), the wind, moving water (hydropower, wave and tidal energy), heat below the surface of the earth (geothermal energy), biomass (wood, waste, energy crops).

1 Not for profit consultancy established in 1998 as a partnership between the South and North Tipperary Local Authorities and the Tipperary Institute. 2 A joint County Tipperary Development Plan will be prepared in due course for the County.

Figure 1: SEAI Methodology for Renewable Energy Strategies


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Renewable energy resources are clean sources of energy. They can be harnessed without damaging the environment, unlike the use of fossil fuels which release carbon dioxide (a greenhouse gas) and other harmful pollutants into the atmosphere. As part of the European Union (EU) Ireland has committed (under the Kyoto Protocol) to increasing the use of renewable energy in order to reduce the production of greenhouse gas emissions. Renewable energy resources are local resources indigenous to the country. Ireland is currently heavily reliant on fossil fuels with approximately 89% of the fuels needed for energy imported into the country. By tapping into the renewable energy resources of the county, this reliance on imports can be reduced. Different forms of renewable energy have different uses; wind (onshore and offshore), hydropower (run-of-the-river and pumped storage) and solar photovoltaic are used to generate electricity, and wave and tidal have potential to do so in the future. Geothermal and biomass energy can be harnessed to contribute to both heat and electricity. Solar thermal energy is generally used for water and space-heating. Biomass is particularly useful for the heat sector (e.g. biomass-based district heating, wood chip boilers, etc), but can also be used to generate electricity. Liquid biofuels currently contribute to the transport sector, while gaseous biofuel (in the form of biomethane) may contribute to the transport sector in the future.

Figure 2: Anaerobic Digestion at Farm Scale in County Limerick

Renewable energy production can be carried out at the large commercial scale for export to the national grid etc or can be produced at the small scale (often called micro generation/auto-production) for private/domestic consumption. Whist some areas of the county may not be suitable for large scale renewable energy projects, generally micro-level projects are suitable in all areas. Such generators can be suitable for directly serving the


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electricity and heat needs of consumers on scales ranging from individual residences to small business or industrial premises. County Tipperary has good potential for the production of renewable energy locally and ready markets for the use of energy from renewable sources in its agricultural and commercial sectors and its settlements. The most familiar source of renewable energy to most people are the commercial wind turbines located on uplands areas, however, there is also significant potential for the production of energy from other renewable sources. The typical renewable resources of South Tipperary are identified below:

1.1.1 Wind Energy

Tipperary has a significant wind resource as determined by ESB Ireland (ESBi) Wind Energy Resource Mapping 3

1.1.2 Bio-Energy

. The potential for wind energy harvesting has been traditionally associated with upland areas; however, with evolving technology and higher turbine heights etc wind energy can now be exploited at lowland locations. The development of micro-level electricity generation from wind energy also has the potential to contribute positively to renewable energy production in the county at both the domestic and commercial scale and in lowland or urban areas.

Biomass is defined in the Renewable Energy Directive 2009/28/EC as the biodegradable fraction of products, waste and residues from agriculture (including vegetal and animal substances), forestry and related industries including fisheries and aquaculture, as well as the biodegradable fraction of industrial and municipal waste, it also includes energy crops such as oilseed rape and willow etc. Biomass can be used to generate electricity, heat and transport fuels. The bio-energy sector in South Tipperary will play a key role in the delivery of renewable heat and renewable transport energy targets. The three main categories of bio-energy are biomass, bioliquids and biofuels. South Tipperary has potential to produce biomass through its agriculture, forestry, and related industries and from the biodegradable fraction of industrial and municipal waste produced in the county.

1.1.3 Hydropower

Hydroelectricity is electricity derived from the power harnessed from the flow of falling or flowing water, typically from streams and rivers through impoundment or diversion

3 Produced by ESBI for South Tipperary County Council

Figure 3: Wood Pellets from Biomass sources


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channels, or in the form of pumped hydro schemes. Hydropower facilities can range from small systems for domestic use to large projects producing electricity for communities or industry. As an inland county, South Tipperary has no coastline and no significant tidal estuaries, therefore, the potential benefit for the production of electricity from hydropower is limited to streams and rivers and where appropriately sited, pumped hydroelectric energy schemes in upland areas .Turlough Hill, built in 1974 is Ireland’s only Pumped Hydro Energy Scheme (PHES), however, there has been renewed interested in the generation of electricity from such schemes as they can provide a constant source of power that can support generation of power from intermittent wind resources. PHES usually requires upland areas capable of accommodating two water reservoirs with a steep gradient in-between to produce ‘head’. Low-cost off-peak electric power is used to run the pumps, and the stored energy can be used for load balancing.

1.1.4 Solar Energy

There are two main forms of solar energy generation: thermal solar energy (passive & active) and photovoltaic (electricity). The National Renewable Energy Action Plan (NREAP) envisages that solar power will make a contribution to Irelands 2020 renewable electricity requirements, it is envisaged that in South Tipperary the production of solar energy will focus on the use of solar thermal panels at both the domestic and commercial scale. The use of solar photovoltaic (PV) will increase as return for energy produced improves and cost of technology decreases.

1.1.5 Geothermal Energy

Geothermal energy means energy stored in the form of heat beneath the surface of solid earth. Geothermal energy is generally classified as either 'deep' or 'shallow’ depending on the depths involved. It may not be economically feasible using current technologies to produce energy from deep geothermal systems in Tipperary, however shallow geothermal energy has been successfully harnessed by some homes and other buildings (such as swimming pools) for heating purposes.

1.1.6 Combined Heat and Power

Combined Heat and Power (CHP) is a technology that uses the energy produced in the combustion of fuel to produce both useful heat energy and electricity. CHP can refer to gas fired CHP or to biomass CHP. Biomass CHP is a form of renewable energy. It is most often used to increase the total amount of useful energy that is produced from fuel when it is burned.

1.1.7 Micro-generation

Micro-generation has been described as the generation of zero or low-carbon heat and power by individuals, small businesses and communities to meet their own needs. ESB Networks consider micro generation as grid connected electricity generation up to a maximum rating of 11kW when connected to the three phase portion of the distribution grid (400V). ESB Networks currently offers consumers a micro-generation feed-in tariff support scheme where the micro-generator conform to the 'Conditions Governing the Connection and Operation of Micro-generation' published by ESB Networks. A micro-generator might use any one of the following technologies to generate electricity:

http://www.esb.ie/esbnetworks/en/downloads/conditions_governing_the_connection_and_operation_of_microgeneration_131106.pdf�

http://www.esb.ie/esbnetworks/en/downloads/conditions_governing_the_connection_and_operation_of_microgeneration_131106.pdf�


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• Wind turbine • Photovoltaic panels (also known as solar

electric panels) • Micro-hydro (scaled down version of hydro-

electricity station) • Micro-CHP (fuelled by biofuels or fossil fuels)

Planning exemptions were introduced in early 2007 and 2008 through the incorporation of Statutory Instruments (SI) 83 of 2007 and SI 235 of 2008 and apply to wind turbines, solar panels, heat pumps and biomass, subject to certain conditions in each case. These exemptions aim to encourage the use of small-scale renewable technologies. Further details on these planning exemptions may be acquired from the planning office or one-line at www.environ.ie.

1.1.8 Hybrid Renewable Energy Systems

Two or more of the technologies may be combined to create a hybrid system. For example, domestic and small commercial wind micro-generation involves using a small-scale wind turbine system to harness energy from the wind, where wind energy is not practical photovoltaic panels might be considered etc. The Irish Wind Energy Association have published useful supporting information on the development of small scale wind energy, further details may be soured at www.iwea.ie.

1.2 Why prepare a RES?

The European Community Renewable Energy Directive 2009/28/EC sets out the basis for achieving the EU’s 20% renewable energy target by 2020. Ireland’s National Renewable Energy Action Plan 2013-2020 (NREAP) sets out how Ireland intends to achieve the individually binding national renewable energy (RE) target of 16% of energy demand by 2020 to be from renewable resources, through 40% of electricity consumption, 10% of transport energy and 12% of heat energy4

. To achieve these agreed European targets, the delivery of renewable energy infrastructure and the production of renewable energy will have to undergo a substantial transformation at both the national level and also at the county level.

It is an objective of the NREAP that local authorities facilitate the growth in production of renewable energy and that a consistent approach to planning and development is employed at the local authority level in Ireland, it aims to achieve this through the application of the SEAI Guidelines for Local Authority Renewable Energy Strategies at the county level. It should also be noted that European and National legislation with respect to Climate Change and Renewable Energy is incorporated into Irish Planning law and the Planning and 4 Refer to Appendix 3 for details of the NREAP targets

Figure 4: Irish Wind Energy Association Guidelines

http://www.environ.ie/�

http://www.iwea.ie/�


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Development (Amendment) Act 2010 introduced legislation with respect the need to reduce energy demand, reduce GHG emissions and to consider the effects of Climate Change through the Development Plan framework, as follows: Section 10 (2)(n) the promotion of sustainable settlement and transportation strategies in urban and rural areas including the promotion of measures to— reduce energy demand in response to the likelihood of increases in energy and other

costs due to long-term decline in non-renewable resources, reduce anthropogenic greenhouse gas emissions, and address the necessity of adaptation to climate change; in particular, having regard to

location, layout and design of new development;

In view of the NERAP 2020 targets and stated actions, recent changes to Planning and Climate Change legislation, and anticipation of growth in the area of renewable energy production in the county, it is now considered best practice for South Tipperary County Council to develop a RES. The RES will put renewable energy to the forefront in achieving sustainable development and ensure that a sustainable framework is in place for the development of the renewable energy industry. This RES will further assist South Tipperary County Council, the wider community and the economy in addressing the following:

• Decrease dependency in the county on imported fossil fuels, • Maintain security of energy supply in the county • Reduce CO2 emissions • Take a proactive and positive approach. The South Tipperary RES can be used as an

example for the development of RES in other inland counties. • Encourage employment and rural development • Support local industry • Encourage local co-operation amongst suppliers of biomass feedstocks, processors,

equipment suppliers, retailers and consumers • Meet the legislative requirements of EU Directives.

1.3 Stakeholders

The value of this RES will be determined by the use it is put to by project developers and other participants in the energy industry. With this in mind, it was considered important that there would be a high level of awareness of the RES both during the preparation phase and following its adoption. The RES can be used as a vehicle to attract development within the local authority administrative area. Ideally, it is intended that the RES would be consulted by developers prior to any major investment in land or project development, such that the RES forms an early and fundamental project assessment and development input. It is also intended that the RES and the associated Environmental Report and Habitats Directive Assessment would be consulted by those interested in the sustainable development of the county and the protection of its cultural and material assets.


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Consultation with stakeholders formed a key part of the preparation of this RES. The Draft RES was prepared after initial pre-Draft consultation (February/March 2013) with the key stakeholders associated with renewable energy and the general public. Written submissions were invited and all submissions were summarised and considered during the preparation of the Draft, a list of persons who made submissions is set out in Appendix 2. A second phase of consultation (November /December 2013) was carried out after publication of the Draft RES and submissions were again invited. All submissions were summarised and considered as part of the preparation of the final RES and a list of persons who made submissions is set out in Appendix 2. Consultation with the statutory environmental authorities was carried out during the scoping phase for Strategic Environmental Assessment (SEA) and Habitats Directive Assessment (HDA). It was decided that SEA and AA were required for the RES and consequently consultation was carried out with the environmental authorities at both pre-draft and draft stage. A summary of submissions made by the environmental authorities may be viewed in the Environmental Report Section 6.3. The Strategic Policy Committee (SPC) for Planning and Economic development have been closely involved in the preparation of the RES and the RES was discussed and reviewed at each of the scheduled SPC meetings held in 2013, the final RES being approved by the SPC at their February 2014 meeting. Consultation has also been carried out with the elected members of the Council, a presentation to the Council at their November Council meeting

Figure 5: Renewable Energy Excursion 15th Apr 2013


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outlined the Draft RES prior to its public consultation period and the final RES was approved by South Tipperary Council at its March 2014 meeting. In order to see a variety of renewable energy technologies in operation, two field trips to renewable energy installations were organised by TEA and South Tipperary County Council and were attended by elected members of South Tipperary County Council, members of the SPC and officials of the Council. The first excursion took place on the 15th April and the day included a visit to Templederry Community Windfarm and Gurteen Agricultural Collage (willow plantation and biomass burner), and a presentation by David McDonnell on his GreenGas Anaerobic Digester Plant at Shanagolden. The second excursion took place on the 23rd January 2014 and the day included a visit to Lisheen Windfarm (community gain and involvement) and Dwan’s Hydropower facility at Holycross. Presentations were given on solar photovoltaic systems and biomass potential in South Tipperary.

Figure 6: Renewable Energy Excursion 23rd January 2014

1.4 Format of this RES

This RES is set out in seven Chapters with four Appendices set out to the rear. Appendix four contains the Environmental Report and Appropriate Assessment. Chapter 1 introduces the RES and the reasons why it is being produced for South Tipperary, the SEA statement is also included in Chapter 1. Chapter 2 deals with the policy framework that defines the requirement to put in place a framework for the promotion and development of renewable energy. It also explains the interaction of this RES with other related projects and initiatives at the county level. The process of Strategic Environmental Assessment (SEA) and Habitats Directive Assessment (HDA) is also addressed in Chapter 2. Chapter 3 identifies the county renewable energy resources, current planning policy & typical barriers to renewable energy development in the county.


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Chapter 4 identifies current future energy demand and current levels of energy production. It then goes on to identify the renewable energy potential of the county to 2020. This process is entitled an energy balance and the data was provided by the TEA. Chapter 5 identifies the infrastructural assets of the county and their relationship with renewable energy production. Similarly, the environmental constraints for renewable energy production are discussed (extracted from the SEA and HDA process). Chapter 6 identifies national supports for renewable energy production, the economic and community benefits and opportunities arising from the production and use of renewable energy and renewable energy technology is addressed. Chapter 7 sets out a vision for renewable energy in South Tipperary and gives recommendations as to how South Tipperary could develop the industry in a sustainable manner through a set of strategic targets. Based on this consideration is given to planning policy development.

1.5 SEA Statement

The Planning and Development (Strategic Environmental Assessment) Regulations 2004 require that following the adoption of a plan or programme, the plan making authority makes a Strategic Environmental Assessment (SEA) Statement available to the public and environmental authorities. The SEA Statement is required to include information summarising:- 1) How environmental considerations have been integrated into the Plan; 2) How the Environmental Report, submissions and observations made to the Planning

Authority on the Plan and Environmental Report have been taken into account during preparation of the Plan.

3) The reasons for choosing the Plan, as adopted, in the light of the other reasonable alternatives dealt with and,

4) The measures decided upon to monitor the significant environmental effects of implementation of the Plan.

1. How environmental considerations have been integrated into the Plan. The Environmental Report highlighted the following development types that could give rise to pressure on the environment;

• All forms of Micro renewable energy resource collectors – Private wind turbines, solar panels, private combined heat and power units, small scale anaerobic digestion etc.

• All forms of Macro-renewable energy resource collectors and renewable energy production industries, associated with wind energy, hydropower, biomass, solar energy etc.


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Having consideration to the potential for impact on the environment, an exercise was carried out to assess the extent of impact on the environment as a result of renewable energy development. Potential impacts were categorised (see section 6.4) as follows:

√ Significant beneficial impact ? Uncertain Impact X Significant adverse impact O No relationship, or insignificant impact.

It was found that no significant adverse impacts would arise; however, it was found that uncertain impacts could arise on Biodiversity, Water Quality/Flooding, Landscape/Visual Amenity and Material Assets. Therefore, mitigation measures were incorporated into the RES after consultation with the environmental authorities in order to mitigate uncertain impacts.

2. How the Environmental Report, submissions and observations made to the Planning Authority on the Plan and Environmental Report have been taken into account during preparation of the Plan.

Before the preparation of the Draft RES scoping was carried out with the environmental authorities and comments received were incorporated into the Environmental Report and also informed the Draft RES. After publication of the Draft RES, further consultation was carried out with the environmental authorities. A detailed submission was received from the EPA and this and proposed changes to the Draft are summarised in the ‘Report on submissions’ prepared after publication of the Draft RES.

3) The reasons for choosing the Plan, as adopted, in the light of the other reasonable alternatives dealt with.

Two reasonable alternatives were considered before selection of the alternative chosen. A scenario of not preparing renewable energy policy of any format for county Tipperary was not considered as a viable alternative the County Development Plan already contains policies and objectives that deal with renewable energy. It was considered more appropriate to examine the situation that would arise in the absence of a dedicated RES (baseline) and the proposal to develop this dedicated RES with the TEA in association with the NREAP targets. Baseline Scenario – This refers to a scenario of ‘business as usual’ or alternatively could be described as the situation that would arise in the absence of a RES and would occur where all policy measures legislated for are maintained, however, no proactive approach to renewable energy development and support is considered. This would represent a hypothetical future scenario in which no further policy actions or collaborative measures including all stakeholders are taken. Such an approach would result in a slow increase in the production of renewable energy however, would fail to meet 2020 renewable energy production targets for the reduction in reliance on fossil fuels and the consequent increase in the production of and use of renewable energy.


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NREAP Scenario - This scenario is to occur in line with the implementation of the baseline measures described above and in addition to these, the implementation of the NREAP targets. The NREAP details a pathway for Ireland to meet the binding commitments of 16% Renewable Energy Share of national energy consumption by 2020. The adoption of the NREAP scenario is considered appropriate as the NREAP is the overriding national framework for the development of renewable energy in Ireland and the RES is dedicated to applying this at the local or county level. This alternative was developed in conjunction with the appropriate environmental protection measures and will ensure the sustainable development of renewable energy resources.

4) The measures decided upon to monitor the significant environmental effects of implementation of the Plan.

Monitoring measures are set out in Chapter 7 of the Environmental Report. As the RES supported the objectives of the County Development Plan it is considered appropriate that monitoring for the RES be incorporated into the annual monitoring programme for the County Development Plan.


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2.0 Policy Overview & Legislative Context The context for the RES is set in a hierarchy of international and national legislation which together provides the statutory basis for the preparation of policy for the sustainable development and use of renewable energy sources and for the protection of the environment. At an international level the United Nations Framework Convention on Climate Change (UNFCCC) requires developed countries to put in place policies and measures with the objective of returning emissions of greenhouse gases to 1990 levels. There is a significant risk5

2.1 European Policy

, that Ireland will not meet its 2020 EU emission reduction targets even under an ambitious emission reduction scenario. Strong projected growth in emissions from transport and agriculture are the key contributors to this trend, this illustrates the challenge that faces the Irish government in the area of emissions reductions. The major legislative requirements and policy guidelines are set out below.

2.1.1 Directive 2009/28/EC - Promotion of the Use of Energy from Renewable Sources This Directive of the European parliament and of the Council sets out to ensure that 20% of EU energy consumption will come from renewable resources by 2020, with each country being assigned a legally binding individual target. The Directive required that member states prepare a National Renewable Energy Plan by June 2010. The Directive’s specific target for Ireland is that 16% of the national gross final consumption of energy will comprise energy from renewable sources by 2020 across the transport, heat and electricity sectors, with a minimum of 10% of RE consumed in transport. The Directive requires member states to implement measures facilitating the supply and use of energy from renewable sources at all scales of operation. The National Renewable Energy Action Plan (NREAP) sets out how Ireland will achieve its overall 16% target across the electricity, heat and transport sectors.

2.1.2 EU Targets for non Emissions Trading Scheme (ETS) Sector emissions Under the EU Commission’s Climate and Energy Package6

, Ireland is required to deliver a 20% reduction in non-ETS greenhouse gas emissions by 2020 (relative to 2005 levels). The non-ETS sectors cover those sectors that are outside the EU Emissions Trading Scheme and include the agriculture, transport, residential and waste sectors.

It is estimated that Ireland will exceed its 2020 limit by 5 – 8 M tonnes of CO2eq. In addition, the projections indicate that Ireland will exceed its binding annual limit in 2015-2016 and will exceed its obligations over the 2013-2020 period cumulatively, by 7 – 24 M tonnes of CO2eq. The impact of forest sinks are not included in this assessment in line with EU accounting rules which stipulate that forest sinks may not be used for compliance towards EU 2020 targets. The key contributors to emissions in the non-ETS sectors are transport and agriculture. Agriculture emissions are projected to grow on an annual basis out to 2020 which reflects the impact of Food Harvest 2020 and removal of milk quota. In total,

5 Ireland’s Greenhouse Gas Emission Projections 2012-2030 – EPA April 2013 6 Set of binding legislation which aims to ensure the European Union meets its ambitious climate and energy targets for 2020 – ec.europe.eu


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agriculture emissions are projected to increase by 12% by 2020 on current levels. Transport emissions are also projected to show strong growth over the period to 2020 with a 12- 22% increase on current levels depending on the level of policy implementation. The achievement of emissions reduction targets set out in Government policy documents such as the National Energy Efficiency Action Plan and the National Renewable Energy Action Plan (see below) are vital in achieving emissions reductions goals. However, the difficulties associated with meeting these targets cannot be underestimated. Failure to meet these targets will result in higher emissions levels than those projected7

2.2 National Policy

and result in Ireland’s emission levels moving even further from its emission reduction targets.

2.2.1 Strategy for Renewable Energy 2012-2020, Department of Communications, Energy and Natural Resources

This high level Strategy underpinned by the detailed NREAP, sets out the Government’s strategic goals for renewable energy and the key actions underway and planned in the short and medium term for each of the renewable energy sectors. The key actions are designed to address current challenges and support progressive delivery on our national ambitions for renewable electricity, heat and transport. The NREAP sets out in considerable detail the range of actions underway based on the strategic goals set out below. Strategic Goal 1 Progressively more renewable electricity from onshore and offshore wind power for the domestic and export markets. Strategic Goal 2 A sustainable bioenergy sector supporting renewable heat, transport and power generation. Strategic Goal 3 Green growth through research and development of renewable technologies including the preparation for market of ocean technologies. Strategic Goal 4 Increase sustainable energy use in the Transport sector through biofuels and electrification. Strategic Goal 5 An intelligent, robust and cost efficient energy networks system.

Section 2.2.2 Sustainable Future – A Framework for Sustainable Development for Ireland The publication by the Department of the Environment, Community and Local Government entitled ‘our Sustainable Future – A Framework for Sustainable Development for Ireland summarises Ireland’s Framework for Sustainable Development to 2020. The overall aim of

7 Ireland’s Greenhouse Gas Emission Projections 2012-2030 – EPA April 2013


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Our Sustainable Future is to provide for the integration of sustainable development into key areas of policy, to put in place effective implementation mechanisms and deliver concrete measures to progress sustainable development. The objectives of the Framework are to:

• Identify and prioritise policy areas and mechanisms where a sustainable development approach will add value and enable progress towards the strategy aims. Highlight and promote existing sustainable practices that, with the correct support, can underpin sustainable development more generally.

• Strengthen policy integration, coherence and co-ordination and bring a long term

perspective to decision making.

• Set out governance mechanisms which ensure effective participation within government and across all stakeholders.

• Set out clear measures, responsibilities and timelines in an implementation plan.

• Set out how progress is to be measured and reported on through the use of

indicators.

• Incorporate adequate and effective monitoring, learning and improvement into the Framework process.

2.2.3 The National Renewable Energy Action Plan (NREAP) 2010 Ireland’s NREAP to 2020, is the framework within which Ireland has set out the detailed schemes, policies and measures underway and planned to deliver energy growth from renewable sources. Ireland is obliged to report to the EU Commission on progress (as well as obstacles to progress). The first such Report8

(January 2012) outlines progress to date including updates on policy and regulatory changes and sets out the challenges still to be addressed.

The Government plans that by 2020 the overall binding target will be delivered by approximately 40% consumption from renewable sources in the electricity sector (RES-E), 12% in the heat sector (RES-H) and 10% in transport (RES-T). The NREAP requests that local authorities consider the actions and targets of the NREAP and identify how it is intended to contribute to the achievement of these targets at the local authority level, particularly in the context of renewable energy resources that are available.

2.2.4 The National Climate Change Strategy (2007-2012) The National Climate Change Strategy was published in 2007 by the Department of Environment, Heritage and Local Government. This strategy includes existing measures put in place by the previous National Climate Change Strategy 2000, the National Development

8 Refer to www.dcenr.gov.ie for details of progress reports. The first progress report was published in January 2012.

http://www.dcenr.gov.ie/�


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Plan 2007-2013, Transport 21, the Energy White Paper and the Bio-Energy Action Plan, and will enable Ireland to meet its emissions reduction commitments.

2.2.5 National Energy Efficiency Action Plan: Maximising Ireland’s Energy Efficiency, 2013-2020 (NEEAP)

The NEEAP was first published on 8 May 2009 by the Department of Communications, Energy and Natural Resources and updated in 28 February 2013. It aims to create a 20% more energy-efficient Ireland. Targets include: reducing public sector energy consumption by 33%, and providing tax incentives to businesses and grants to residences to increase energy efficiency. The NEEAP helps to shape the backdrop against which renewable energy projects are delivered. Over the past few years’ energy demand and consumption in Ireland has fallen as a result of the economic crisis however, energy savings have also been delivered through national energy efficiency measures. The NEEAP sets out the Government’s ambitions to deliver further energy savings over the period to 2020. Better energy efficiency is closely intertwined with a move away from energy from fossil fuels to energy from renewable resources, thus the implementation of measures under both the NREAP and the NEEAP are equally important in achieving Irelands’ EU emissions commitments.

2.2.6 Bioenergy Action Plan for Ireland (2007-2020) The Bioenergy Action Plan was produced by the Department of Communications, Marine and Natural Resources in 2007 and sets out an integrated strategy for collective delivery of the potential benefits of bioenergy resources across the agriculture, enterprise, transport, environment and energy sectors. It requires sustained multi-agency collaboration, at national, regional and local level, working in strategic alliances to ensure that the potential for bioenergy production is realised.

2.2.7 National Spatial Strategy 2002 (NSS) The NSS was first produced in 2002 by the Department of Environment and Local Government and is the 20-year framework for the spatial development of Ireland. The NSS is currently under review however, the requirement for balanced spatial growth is still of fundamental importance in achieving sustainable development and efficient energy consumption.

2.2.7 The Planning and Development (Strategic Infrastructure) Act 2006 The Planning and Development (Strategic Infrastructure) Act 2006 deals with strategic development and strategic infrastructure. It provides for, among other things, the establishment of a streamlined consent procedure for certain types of major infrastructure and identifies An Bord Pleanála as the decision maker in relation to such projects. The Act provides a list of the development types that are considered to qualify for this treatment, including a range of renewable energy infrastructure and the supporting infrastructure that can facilitate the deployment of renewable energy projects (such as power lines to support wind energy generation above a certain scale/rating). The Act is designed to ensure co-ordination between local, regional and national authorities which balance local interests with the national imperative to deliver strategic infrastructure.


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2.2.8 The Planning and Development (Amendment) Act 2010 This Act builds on provisions of existing Planning Acts and Regulations in terms of renewable energy planning. Exemptions exist for certain domestic micro-renewable energy technologies and also for renewable energy technologies for use in industrial, commercial and agricultural settings. Specific exemptions are provided for wind turbines, met masts, CHP plants, solar panels and biomass boiler units. The explicit provisions for exemptions are based on technology and circumstance for renewable energy production, and should be consulted in advance of any proposal.

2.2.9 Part L of the Second Schedule of the Building Regulations 1997 – 2008 Part L of the Building Regulations 2008 specifies that “a reasonable proportion of the energy consumption to meet the energy performance of the dwellings is provided by renewable energy sources”. The regulations aim to increase the use of renewable energy in domestic dwellings. A Strategic Framework to achieve a carbon neutral standard for dwellings by 2013 is also being developed by the Department of Communication, Energy and Natural Resources. It is proposed that the use of onsite renewables and energy efficiency measures such as better insulation and energy efficiency design (both new build and retrofitting) will be a key element of the framework.

2.2.10 Wind Energy Guidelines and update The Minister of the Environment, Heritage and Local Government issued Wind Energy Guidelines in 2006 under Section 28 of the Planning and Development Act, 2000. Planning authorities and An Bord Pleanála must have regard to such guidance in the performance of their functions. The Department of the Environment, Community and Local Government in conjunction with the Department of Communications, Energy and Natural Resources is currently undertaking a technical update of the guidelines with respect the areas of noise and shadow flicker. This update is intended to ensure that the Wind Energy Guidelines are supported by a robust and up to date evidence base on these issues to support wind energy development in a manner which safeguards residential amenity consistent with EU and National Policy. For more details on this process please refer to www.environ.ie.

2.3 Regional and Local Policy

2.3.1 South East Regional Planning Guidelines The South East Regional Planning Guidelines were adopted in 2010 and provide a long-term strategic planning framework for the development of the South-East Region for this period and to guide and inform the Development Plans and Local Area Plans of the local authorities in the region. The Guidelines will guide the future development of the region for the next 20 years and address the growth and development of the region including energy efficiency and renewable energy.



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Section 6 of the Regional Planning Guidelines is entitled ‘Communications, Energy, Regional Climate Change Strategy’ and it is stated that the South-East Regional Authority actively and strongly supports the sourcing and generation of energy from within the South-East. It is an objective of the Guidelines that local authorities, the private sector, energy production and supply companies are encouraged to formulate sustainable energy policies and practices which seek to:

a) Ensure security of energy supply in order to support economic and social development;

b) Source energy at a price that does not adversely affect competitiveness; c) Develop variable and alternative sources of energy generation; d) Maximise the use of renewable energy technologies; e) Promote a culture of energy conservation by all users; f) Assist the development of indigenous sustainable energy enterprises; g) Support and promote sustainable indigenous Bio-energy industries including the Bio-

ethanol industry.

Figure 7: Location of South East Region


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2.3.2 South East Regional Authority Bio-Energy Implementation Plan 2013 The South East Bio-Energy Implementation Plan Review 2013 sets out targets of 5% of total energy supply from biomass by 2010 and increasing to 17% by 2020. Future development within the bio-energy sector is regarded as an area that has significant employment and energy import substitution potential. In this regard the Regional Authority supports the investigation of the potential for using wheat, barley and sugar beet for biofuel.

2.3.3 South Tipperary County Development Plan 2009 The South Tipperary County Development Plan 2009 is informed by the South East Regional Planning Guidelines and sets out the statutory planning framework for the sustainable development of the county. The County Development Plan is the statutory framework for planning policy for the County and this RES supports the policy and objectives of the County Development Plan with respect to the development of the renewable energy sector. A new amalgamated County Development Plan will be prepared for the entire county of Tipperary in due course9

2.4 Related Renewable Energy Initiatives

and will also be informed by the policy approach and vision outlined in this RES.

The TEA are actively involved in programmes and measures (some of which are connected with partners in Europe), that are dedicated to promoting greater use of renewable energy resources and better energy efficiencies. Some of these programmes include:

South Tipperary County Council Climate Change Strategy

South Tipperary County Council has prepared its own Climate Change Strategy, which is an initiative aimed at complying with the requirements of the National Climate Change Strategy. The strategy has been prepared by the Council’s Climate Change and Energy Management Committee, which is representative of all relevant sections of the Council and has representatives from the South Tipperary Local Authorities. The committee has been assisted in its work by the TEA, which has played a key role in progress to date. The intention of the strategy is to focus on the Council’s activities and to define practical steps for direct action by the Council with timetables and targets. In compiling the strategy the Council looked at its work programme with a particular focus on where its own activities impact on climate change.

TEA ACE Project

The Academy of Champions for Energy (ACE) project seeks to strengthen communities through improving the engagement of citizens and their energy. It seeks to learn from the best Pan EU methods of developing community energy through new business models and citizen engagement. The TEA are partners in this European project.

Covenant of Mayors

The Covenant of Mayors is a European movement involving local and regional authorities, voluntarily committing to increasing energy efficiency and use of renewable energy sources on their territories. By their commitment, Covenant signatories aim to meet and exceed the 9 A new Joint County Development Plan for Tipperary will be prepared after the county is amalgamated.


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European Union 20% CO2 reduction objective by 2020. The TEA represents South Tipperary on this movement. It is envisaged that TEA will assist in the submission of an application to the Covenant of Mayors on behalf of the amalgamated Tipperary Local Authorities post 2014 as a sign of commitment to the environmental principles of the movement.

Tipperary Micro-Local Bioenergy Action Plan, 2013

TEA are partners on the POLI-Biomass Interreg Project which aims to:

• review the status of energy policies in Europe and identify best practice • develop local action plans in three municipalities in Europe • exchange experiences and knowledge amongst partners and relevant stakeholders.

The TEA Tipperary Micro-Local Bioenergy Action Plan 2013 was produced under this programme.

2.5 Strategic Environmental Assessment and Habitats Directive Assessment (Appropriate Assessment)

2.5.1 Strategic Environmental Assessment (SEA)

Strategic Environmental Assessment (SEA) is the process by which environmental considerations are integrated into the preparation and adoption of certain plans and programmes. The legislation relating to SEA in the Irish context may be found in SI 435 of 2004, European Communities (Environmental Assessment of Certain Plans and Programmes) Regulations 2004 and SI 436 of 2004 Planning and Development (Strategic Environmental Assessment) Regulations 2004, as amended by S.I. No. 200 of 2011, European Communities (Environmental Assessment of Certain Plans and Programmes) Amendment Regulations 2011, and S.I. No. 201 of 2011, Planning and Development (Strategic Environmental Assessment) Amendment Regulations 2011. The protection of the environment from inappropriate development is fundamental to the development of any plan or strategy in South Tipperary and this RES has incorporated SEA to ensure that environmental considerations are integral to this plan for renewable energy development. It will be a key aim of South Tipperary County Council to balance the protection of the environment and local communities from unsustainable development whilst at the same time contributing to the achievement of Ireland’s emissions reductions targets. Scoping of the SEA was carried out in consultation with the statutory consulates in January 2013 to identify the range of environmental issues and the level of detail to be included in the environmental report. It was found that the environmental areas of focus were;

o Biodiversity, Flora and Fauna, o Water quality and flood risk management, o Landscape and visual amenity, and, o Material assets.


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The Environmental Protection Agency set out their recommendations with respect preparation of the RES; the key recommendations are set out in the Environmental Report accompanying this document. The SEA process informed the RES within respect to alternative scenarios for renewable energy production in the county and also the process of how certain areas were identified or excluded for the purposes of renewable energy. The focus of the SEA process was on the environmental areas identified at scoping stage. Where appropriate mitigation measures were outlined and are incorporated into the policy proposals set out for renewable energy developments to ensure that no adverse impacts would arise as a result of the implementation of the RES.

Flood Risk Assessment

Flood Risk Assessment is an integral element of the SEA process. In this respect the local authority has considered the Planning System and Flood Risk Management: Guidelines for Planning Authorities, 2009 as set out by the Department of Environment, Community and Local Government (DECLG) and the Office of Public Works (OPW). The OPW is the lead agency for flood risk management in Ireland and is the national competent authority for the EU Floods Directive. The OPW works in close partnership with all Local Authorities in delivering the objectives of the Catchment Flood Risk Assessment and Management (CFRAM) Programme. In carrying out the SEA process reference was made to the Preliminary Flood Risk Areas (PFRA) compiled by the OPW and flood risk mapping for South Tipperary prepared by JBA Consultants. Flood Risk Management Plans (FRMPs) will be developed by the OPW by 2016. FRMPs will include measures in relation to flood prevention, protection and preparedness. Emergency response to flooding, recovery from flooding and incorporating lessons learned will be important elements of the FRMPs. Issues such as climate change, land use practices and future development will also be addressed in the FRMPs. It will be a key objective of the local authority that renewable energy development does not contribute to flood risk in the county.

2.5.2 Habitats Directive and Appropriate Assessment

Appropriate Assessment (AA) is the process that requires the competent authority to assess the possible nature conservation implications of any plan or project, alone and in combination with other plans or projects that might affect any Natura 2000 site. The requirement to undertake an AA is derived from Articles 6(3) and 6(4) of the Habitats Directive and Section 5 of SI No. 477 of 2011, European Communities (Birds and Natural Habitats) Regulations 2011. ‘Plans’ include all statutory and non-statutory land use and framework and sectoral plans and strategies to the extent that they have the potential to have significant effects on a Natura 2000 site. Article 6(3) requires that any plan or project that is not directly connected with or necessary to the management of the Natura 2000 site concerned but is likely to have to be authorised only if it will not adversely affect the integrity of that site. It was considered that AA was required for the RES as significant impacts on Natura sites may

http://www.opw.ie/�


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occur as a result of the implementation of the RES, either on its own or in combination with other plans or projects. The purpose of the AA will be to ensure that existing and future plans or projects are not authorised if they are likely to adversely affect the integrity of a Natura site. To assist planning authorities, the Department of the Environment, Heritage and Local Government (DECLG) published Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities (2009). The AA process for the RES outlines mitigation measures to preclude direct and indirect effects on any Natura 2000 sites from proposed renewable energy developments. In addition, it recommends that individual projects be subject to AA Screening and preparation of a Natura Impact Statement, where appropriate. The RES contains information on how the AA processes informed the preparation of the RES. As both an AA and SEA are required for the RES, the processes and consultation activities for both were aligned and carried out concurrently.


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3.0 County Renewable Energy Resources, Planning Policy & Barriers

As already stated above, South Tipperary has the potential to support a sustainable renewable energy industry, subject to appropriate guidance and management. Renewable energy generation in South Tipperary can accommodate commercial scale renewable energy installations for export to the national grid, or micro or small scale installations for domestic or local use. A micro generator might use any one of the following technologies to generate electricity:

• Wind turbine • Photovoltaic panels (also known as solar electric panels) • Micro-hydro (scaled down version of hydro-electricity station) • Micro-CHP (fuelled by biofuels or fossil fuels).

ESB Networks will accept micro-generation applications for energy generators up to 6kW, generators above this size must apply for a grid connection to Eirgrid through the Gate process. It is an objective of the County Development Plan that consideration is given to the installation and use of technologies that can provide energy from renewable resources at a micro-scale. Both large scale and micro-scale technologies are described below. Further detail on the key renewable energy resources, current policy approaches and barriers to development are addressed below;

3.1 Wind

South Tipperary County Council adopted its Wind Energy Policy in 2006 when it was inserted into the County Development Plan by way of variation. The development of the County Wind Energy Policy was carried in line with the Wind Energy Guidelines produced in 2006 by the Department of Environment, Heritage and Local Government. The South Tipperary County Council Wind Energy Strategy for wind energy development was prepared by Cunnane Stratton Reynolds and the development of the Strategy was informed by the Landscape Character Assessment (LCA) – Phase 1 - Uplands10

also prepared by Cunnane Stratton Reynolds for the uplands of the county. A detailed Strategic Environmental Assessment was prepared by Fehily Timoney & Co and this ensured that the Wind Energy Strategy and subsequent wind energy development would have the minimum impact on the environment. Wind resource mapping was prepared for the county by the Electricity Supply Board International (ESBI), this was utilised to identify the areas of greatest wind speeds and therefore greatest potential for wind energy harvesting.

10 The Phase 2 LCA - Lowlands, is being developed in conjunction with this RES and will inform countrywide policy on landscape.


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A detailed selection process was carried out to identify the wind energy potential of the county, this included consideration of environmental constraints to wind energy development i.e. proximity to Natura 2000 sites, proximity to settlement and infrastructure, landscape sensitivity etc and technical factors in wind production including average wind speeds, topography, available infrastructure etc. The current wind energy resource is therefore a based on an assessment of facilitators, and environmental and infrastructural constraints to wind energy development. Notably, there are parts of the county considered suitable, open for consideration and unsuitable for wind energy development. Unsuitable areas are those categorised as very high amenity, iconic landscapes and areas of consideration historical and heritage importance. The Wind Energy Strategy was incorporated into the County Development Plan in 2006 after a detailed public consultation process, and this wind energy policy remains in force in the current South Tipperary County Development Plan 2009-2015. Refer to Figure 8 for a map of areas where wind turbines have been permitted and Appendix 3 for Map of wind energy areas.

The development of commercial wind energy resources in South Tipperary has been relatively successful to date with 84 commercial scale turbines permitted in the county in upland areas including the Holyford Hills, Slieveardagh, Kilhill near Dualla, and the Cappawhite Hills. Approximately half of these turbines are either in operation or under construction.

Barriers for development of wind energy in the county include:

• Public resistance to wind farm development, this may be exacerbated by lack of adequate information and the common perception that there is no benefit to the local community as a result of wind energy developments.

Figure 8: On-Farm Turbines at Shanagolden, County Limerick


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• Environmental concerns including noise, impact on designated areas and species, visual impact, cumulative impact in areas where turbines have already been permitted, impact on animals including horses, electromagnetic interference and shadow flicker etc.

• The high cost of renewable energy technologies and the difficulty in acquiring capital finance, coupled with the long planning and development phase associated with wind energy development.

• Difficulty in acquiring connection to the national power grid through the Gate process and low return on power generated through the REFIT scheme.

• Future uncertainties with respect approach to planning and development of wind turbines, for example, alteration to current planning policy at either the county, regional of national level.

Opportunities for development of wind energy in the county include:

• South Tipperary has a good wind resource in comparison with other inland, low-lying and heavily populated counties in the country.

• Employment opportunities and financial return for landowners, investors and communities through from the sustainable generation of energy from wind resources.

• As the country can generate far more electricity from wind power than it can consume it is possible in the future that Ireland will become a net export of energy generated from wind through investment in an electricity interconnector between Ireland and the UK/Europe. South Tipperary could benefit from the construction of such infrastructure.

Figure 9: Locations of permitted commercial wind farm


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3.2 Bioenergy

The development of the bioenergy resources of South Tipperary and the South East region are addressed in two recent publications. The South East Regional Authority Bio-energy Action Plan review 2013 identifies the bio-energy resources for the region and opportunities for their development. This document may be viewed at www.sera.ie. The TEA produced in 2012 a Tipperary Micro Local Bio-Energy Action Plan a project co-funded as part of a European Interreg project. This local bioenergy project examined in detail bio-energy in South Tipperary. For detailed information on the BioEnergy Action Plan refer to www.tea.ie. Energy from biomass as defined earlier has a number of potential sources and can be utilised on a domestic, industrial, agricultural and commercial scale. This section identifies some of the potential sources of energy that may contribute to energy production in South Tipperary and the current policy approach to such development.

Figure 10: Biomass Resource in form of Timber

Wood Biomass South Tipperary has upland forestry plantation resources in its upland areas; these can provide wood biomass in the following forms:

• First thinning of plantations, • Forest residues left on site following felling, • Short rotation forestry,

http://www.sera.ie/�

http://www.tea.ie/�


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• Short Rotation Coppice (e.g. Willow) • Co-products such as sawdust, bark and off-cuts arising from sawmilling and board

manufacture, • Untreated recycled wood.

A large wood processing facility located in Clonmel utilises very significant amounts of wood based biomass every year in the form of waste material, and energy produced from two large biomass boilers is also used as a source of power on site.

Agricultural Crop Residues Dry agricultural residues (straw, poultry litter and spent mushroom compost can provide a feedstock for bio-energy production. South Tipperary has a strong arable industry and current total straw production is approximately 47,957t11

Energy Crops

.

The growth of energy crops such as oilseed rape, miscanthus and willow thorough of significance in other counties has had a very limited uptake to date in South Tipperary. However, as demand for and economic return from energy crops improve the growth of such crops will become more common place in the county.

Agricultural and Food Industry Slurry as a feedstock for anaerobic digestion is freely available in Co. Tipperary, with 121,123 cattle including dairy cows in the county. (CSO 2010) Other sources of agricultural waste products arise from the dairy processing and meat processing industries. The high capital cost of anaerobic digestion plants, poor return through the current REFIT tariff and difficulties obtaining a grid connection has slowed the development of anaerobic digestion plants in Ireland.

Sugar Beet Up to 2006 South Tipperary was a significant producer of sugar beet. Should beet processing be reintroduced it is likely that a substantial number of growers would re enter the market as sugar beet provides a lucrative natural break crop in the tillage production cycle. There has been a recent campaign by ‘Beet Ireland’ for the reintroduction of the beet Industry in Ireland with an analysis carried out by the Irish Sugar Beet Bio-Refinery Group on the feasibility of locating a sugar beet processing plant in the South East Region, with the capacity to produce bio-ethanol as well as sugar and a source of cattle feed. The current South Tipperary County Development Plan 2009-2015 supports the development of bioenergy in the county as outlined in the South East Bio-energy implementation Plan12

. In their Energy Policy entitled ‘Irelands land based Renewables Strategy’, the Irish Farmers Association (IFA) state that there are opportunities for the renewable energy and agricultural sectors to work together towards the meeting of Ireland’s 2020 targets for energy.

11 TEA Energy Balance 2013 12 Section 7.8 South Tipperary County Development Plan 2009-2015.


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Barriers for development of energy from biomass in the county include:

• The relatively low prices of fossil fuels especially gas availability in South Tipperary currently makes production of energy from biomass appear non-competitive in the short term.

• Initial capital costs of solid biofuel systems and the interest associated with these costs are much higher than for liquid or gas fuelled systems. This can act as a significant barrier to development of energy production from biomass along with the difficulty in acquiring capital finance.

• Uncertainty as to the availability of biomass resources e.g. farmers doubt the stability of the biofuel market, resulting in a reluctance to change over to the production of energy crops.

• The current financial incentives i.e. REFIT 3 from the Irish government to support renewable energy developments are inadequate to stimulate wide scale development.

• Lack of experience and familiarity with biomass technologies amongst key players such as policy makers, local authorities and resource owners inhibits development of biomass systems in Ireland

• Poor support for research, development and demonstration. Certain biomass technologies e.g. anaerobic digestion are well established and therefore require support for demonstration, while others are at an earlier stage of development and are the subject of research programmes by the Department of Agriculture, Food and the Marine at facilities such as the Oakpark Carlow Teagasc research facility.

Opportunities for development of energy from biomass in the county include:

• Ireland has among the best growth climate in Europe. Ireland’s potential annual yield of wood is almost three times that of Finland, notwithstanding this, Finland’s energy use from biomass is 18%!

• Useful bioenergy can be recovered from wood wastes (e.g. from sawmills), forest residues (e.g. wood chips, bark), household and agricultural residues (e.g. slurry and poultry waste) to generate heat and electricity, while at the same time dealing with the problem of waste disposal.

• Biomass as an energy resource is sustainable and does not deplete future resources. • Energy forestry crops have a much greater diversity of wildlife and flora than arable

or pasture land and careful design of energy crops will enhance local landscapes and provide recreational facilities.

• Research and support in the area of Biomass resources for energy is increasing i.e. Bio resources research centre – UCD, IFA - ‘Irelands Landbased Renewable Energy Strategy’.

3.3 Hydro Power

Due to its upland areas and fast flowing streams and rivers there is potentially a significant unexploited hydroelectricity resource available in South Tipperary. The amount of electricity a hydroelectric site can generate is the product of flow volume and head height. The best sites having large volumes of water all year round, with a large vertical drop in a short distance. PHES using a high head and impoundment of water commonly provide the most


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cost effective generation of electricity. The advantage of such energy generation systems is that the process is a ‘closed’ one, that is once the impoundment i.e. lake is fully charged there is no water loss and no further water abstraction except for water losses through evaporation. At present, there are two grid connected scale hydro power stations located in South Tipperary, both of these are located on the River Suir and are in lowland areas. These are located at Holycross and Clogheen and these have a combined installed capacity of 285kW of power per annum between them. In addition to this there are a number of small scale hydropower facilities that provide on-site power to domestic and commercial facilities. The Department of Communications Energy and Natural Resources and the Central Fisheries Board have released a report entitled “Guidelines on the Construction and Operation of Small Scale Hydro Electric Schemes and Fisheries”. To date there is no PHES in South Tipperary. The REFIT 2 scheme is designed to incentivise the addition of 4,000MW of new renewable electricity capacity to the Irish grid, and power generated from inland water sources is targeted under this scheme along with onshore wind and biogas. It is envisaged that in South Tipperary hydropower will contribute to renewable energy generation along with onshore wind and bioenergy. The SEAI website sets out useful information on how to develop hydropower in Ireland at www.seai.ie.

Figure 11: Illustration of PHES

Barriers for development of energy from hydropower in the county include:

• The high cost of PHES technologies and the difficulty in acquiring capital finance. • The current financial incentives from the Irish government to support renewable

energy installations are generally inadequate. • Difficulty in acquiring and cost of an electrical grid connection and the long planning

and development phase. • A requirement to export electricity to the grid over a large distance may make the

project unfeasible. • Environmental sensitivity of water bodies, designated sites (SAC’s, NHAs, SPAs) and

areas of historic and heritage significance.

http://www.seai.ie/�


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Opportunities for development of energy from Hydropower in the county include:

• PHES compliments a power system with high installed wind energy capacity due to its fast ramp rates, high reliability and availability, its ability to provide reserve.

• South Tipperary has upland areas that may be able to provide the attributes necessary to provide suitable sites for PHES including grid connection and head heights.

• South Tipperary has a history of hydropower production on the River Suir, when hydropower was used to power the milling industries of South Tipperary.

3.4 Solar

The potential for capture of energy from the sun in South Tipperary is limited by the solar radiation available and the current cost of solar energy systems. The annual average global insolation (the amount of energy reaching the surface per square metre) values for Ireland range from 2.6 – 3.0 kWh/m2/Day with South Tipperary on the higher end on this scale. Electricity generation from solar technologies (solar thermal and solar electric) in Ireland is currently underdeveloped and generally limited to domestic systems for water and space heating. The SEAI ‘Greener Home Scheme’ granted aided the installation of solar thermal systems in the county from 2006-2011, in this time approximately 1100 systems were installed through the scheme in County Tipperary. However, the use of solar power for heat generation outside of the domestic sector remains low. Whilst the use of solar power for domestic solar thermal heating systems has been relatively successful to date, there are barriers to the use of solar energy for large scale energy generation.

Barriers for development of energy from solar resources in the county include:

• Solar heating and photovoltaic systems usually require the use of a backup system in periods of high demand. This is a major problem for Ireland as energy requirements are higher in winter when there is less sun.

• Large scale power generation from photovoltaic or concentrating solar technologies may be unfeasible due to low insolation levels in Ireland.

• The initial installation costs for solar power are high and the return can be long-term. • The current financial incentives from the Irish government to support renewable

energy developments are inadequate. • The relatively low prices of fossil fuels especially gas availability in South Tipperary

currently makes production of energy from solar power appear non-competitive.

Opportunities for development of energy from solar resources in the county include:

• Domestic solar water heating systems can provide for 50 to 60% of a household’s hot water demands.

• A domestic solar combi-system can make a useful contribution (30 to 40%) to total heating requirement of the house (both space and water heating).


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• The installation and upkeep of domestic solar installations is relatively cheap and simple, and new research and development in solar systems is lowering the cost of installations.

• The SEAI ‘Better Energy Homes Scheme’ currently grant-aids the installation of domestic solar systems.

3.5 Geothermal

In 2004, a study was performed by the CSA group at the Cork Institute of Technology in Ireland to identify resources of geothermal energy in Ireland. The results of this review indicate that Ireland is particularly well suited for the utilization of ground source heat pumps, due to its temperate climate and rainfall levels that ensure good conductivity and year round rain-fall recharge. The study was completed using existing bore holes in the ground at different locations throughout Ireland. An increase in temperature ranging from 17°C - 19°C was recorded in the south of Ireland and temperatures ranging from 25°C - 27°C were recorded in the north at a depth of 500 metres below the earth’s surface. At a much greater depth of 2,500 metres below the earth’s surface, an increase in temperature ranging from 28°C - 45°C were recorded in the south of Ireland and temperatures ranging from 64°C - 97°C were recorded in the north 13

. The results from this study indicate good potential for commercial development of geothermal electricity in Ireland.

To date there has been limited development of geothermal resources in South Tipperary and installations have been limited to a domestic scale, however, the Geothermal Association of Ireland (GAI)14

Barriers for development of geothermal resources in the county include:

is active in the promotion of the development of geothermal energy in all its forms in Ireland.

• The initial cost of geothermal energy technologies is still relatively high. • Geothermal heat pumps usually require the use of a backup system in periods of

high heating requirements. • Space requirements: The technology requires approximately the same external

ground area as the floor area of the structure to be heated. • The relatively low prices of fossil fuels especially gas availability in South Tipperary

currently makes production of energy from geothermal sources appear non-competitive.

Opportunities for development of geothermal resources in the county include:

• Can be used for both heating and cooling of home, office, industry & districts. • Up to 3-4 units of heat can be produced by heat pumps using 1 unit of electricity. • Geothermal energy is a sustainable and constant energy supply.

13 www.seai.ie 14 http://www.geothermalassociation.ie/


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4.0 Energy Balance & Renewable Potential Assessment

The Tipperary Energy Agency (TEA) has developed a methodology (under the Interreg IVc ACE Project) to assess the current and future energy demand of South Tipperary. Having consideration to this information, it is possible to determine how renewable energy production will contribute to energy requirements in the future; this is entitled a ‘county energy balance’. The county energy balance considers energy produced, consumed and exported and is a valuable tool in setting out objectives for the development of renewable energy development to 2020 and beyond. The units used within the county energy balance and examination of renewable potential are Kilo tonnes of Oil Equivalent (Ktoe)15

4.1 County Energy Demand (baseline and 2020)

.

Figure 11 below illustrates the Total Fuel Consumption (TFC) of South Tipperary. In 2011 this was 207.2 Ktoe, a decrease of 7.2% on 2010 levels and 33% above the 1990 level of 156 ktoe. In line with national figures and despite the economic downturn, it can be seen that fuel consumption in South Tipperary is growing by 1.4% on average annually.

Figure 12: Fuel Consumption 1990-2011 (TEA)

15 A tonne of oil equivalent (toe) is a unit of energy roughly equivalent to the energy content of one tonne of crude oil. The definition in energy terms is that 1 toe = 10 kilocalories = 41.868 gigajoules (GJ) = 11.63 Mega Watt hours (MWh)= 11,630 kilo-Watt-hours (kWh)


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Annual consumption of oil in South Tipperary has fallen since 2008 levels and notably fell by over 10% in 2011 from 2010 levels to 113.4 ktoe. Its share of final energy consumption fell to 55% from over 62% in 1999. Most of this oil was used in transport with the remaining used for thermal energy. Reductions in oil usage can be attributed mainly to the economic downturn since 2008. Despite recent reduced usage, it can be seen that South Tipperary is highly dependent on imported oil as a fuel source, with electricity and gas also contributing significantly to the energy usage in the county. The TEA has identified the five key areas of energy demand in South Tipperary and how energy usage in these areas has changed since 1990.

Figure 13: Key areas of energy demand (TEA) It is evident from Figure 12, that the residential, transport and industrial sectors are the dominant sectors with transport accounting for 32% of Total Fuel Consumption (TFC). The residential and industrial sectors accounted for 30% and 21% of TFC respectively. The commercial sector accounted for 12% of TFC with agriculture being the smallest at 4.5%. The TFC in the transport sector increased by 48% over the period 1990 – 2011, and usage grew on average by 3.1% annually.

4.2 Renewable Energy Production

In the years leading up to 2011 renewable energy use in South Tipperary increased to 2.9% of energy consumption. In terms of energy usage this included the use of biomass i.e. industrial biomass boilers, domestic stoves, rendering plants, wastewater treatment plant biogas etc, wind i.e. commercial and domestic wind turbines, solar energy etc.

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Figure 14: Renewable energy usage in South Tipperary 2011 (TEA) In 2011, biomass and wind energy accounted for the highest percentage of renewable energy both produced and used in the county.

Biomass

South Tipperary energy users and especially domestic users still rely heavily on the use of biomass in the form of timber in stoves and open fires for heat. The use of biomass on a commercial scale is also recorded in the county with at least 10 commercial scale boilers using woodchip and pellets. There is one industrial scale boiler located in Clonmel that accounts for a very high energy usage and uses recycled wood, bark, process waste, wood chip etc. The processing of tallow and biogas also contributes a very small percentage to the amount of energy produced from biomass in the county.

Wind

Energy in the form of electricity from wind accounts for a high portion of renewable energy produced in the county. At the end of 2012, there was approximately 385MW16 of wind energy capacity permitted in South Tipperary, with approximately 63.66MW of this actually installed17

. The Irish Wind Energy Association (IWEA) states that there is a requirement for approximately 2,000MW of new wind capacity in the Republic of Ireland to 2020 in order to ensure that Ireland meets its RES-E target.

It is not possible to identify how much wind energy generation is expected per county, and the potential for each county to produce wind energy is very varied, however to date South Tipperary has adopted a proactive approach to wind energy development in line with its Wind Energy Strategy set out in the South Tipperary County Development Plan 2009. A continued proactive approach to the sustainable development of wind energy is

16 Submission from Eirgrid March 2013 17 IWEA March 2013

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recommended by the IWEA to ensure that South Tipperary can contribute to meeting the national 2020 targets for electricity generated from wind.

Figure 15: Templederry Community Windfarm

Other

It is difficult to quantify the extent of renewable energy produced and used through the other renewable forms including energy from hydropower, solar and geothermal sources. In South Tipperary there are no installations in these categories of a commercial or industrial scale, however, a limited amount of energy is currently produced at the domestic scale from these resources.

4.3 Renewable Energy Potential of the county

Having consideration to current energy demands, dependency on imported fossil fuels and obligations with respect increasing the amount of renewable energy produced and consumed in Ireland it is possible to predict how the growth in renewable energy production will occur. These scenarios are set out having consideration to the nationally binding targets of:

• 40% of electricity consumption from renewable energy by 2020 (RES-E 40%) • 10% of transport consumption from renewable energy by 2020 (RES-T 10%) • 12% of thermal consumption from renewable energy by 2020 (RES-H 12%)

There are two potential scenarios that may occur;


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• Baseline Scenario – This refers to a scenario of ‘business as usual’ and would occur where all policy measures legislated for up to the end of 2010 are maintained. This would represent a hypothetical future scenario in which no further policy actions or measures are taken. Such an approach would result in a slow increase in the production of renewable energy however, would fail to meet 2020 renewable energy production targets.

• NREAP Scenario - This scenario is to occur in line with the implementation of the baseline measures described above and in addition to these, the implementation of the NREAP targets. The NREAP details a pathway for Ireland to meet the binding commitments of 16% Renewable Energy Share of national energy consumption by 2020. In addition, the implementation of the National Energy Efficiency Action Plan (NEEAP) targets in conjunction with the NREAP targets will achieve 20% energy efficiency savings, thus contributing to the achievement of the nationally binding 2020 targets.

Overall energy consumption will be lower for the NREAP scenario than for the Baseline scenario, this is due to the energy efficiency measures to be introduced within the NEEAP, which will have the effect of reducing demand for energy by making more efficient use of current energy usage, this is illustrated in Figure 15 below.

Figure 16: Energy usage to 2020 baseline and NREAP Scenario (TEA)

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Overall energy consumption is set to increase18 for both scenarios to 2020 this is due to a predicated economic improvement and population increase over the course of the years leading up to 2020. Increase in energy consumption will lead to increased emissions, and it has been predicted19

that the key contributors to emissions are transport and agriculture. Agriculture emissions are projected to grow on an annual basis out to 2020 which reflects the impact of Food Harvest 2020 and removal of milk quotas on increased energy consumption. In total, agriculture emissions are projected to increase by 12% by 2020 over current levels. Transport emissions are also projected to show strong growth over the period to 2020 with a 12% - 22% increase on current levels depending on the level of policy implementation.

Having consideration to the requirement for Ireland to meet its renewable energy targets; it is recommended that the NREAP scenario be applied at the county level to 2020 and beyond. This RES sets out the targets for renewable energy based on the requirements of the NREAP. This RES is concerned primarily with the production of renewable energy and thus the targets of the NREAP are most relevant, however, increased efficiency in how energy is used is also important as addressed by the NEEAP and will be addressed in complementary Council policy on energy efficiency and climate change The achievement of NREAP targets by 2020 will require a significant commitment to the use of and production of renewable energy sources as an alternative to fossil fuels especially in the areas of transport and electricity (see Figure 16 below). In South Tipperary the main contributors to electricity will be wind and biomass, heat will continue to be supplied primarily by woody biomass and transport commitments will be met largely by bio-fuel usage and use of electric vehicles.

Figure 17: Increase in consumption of renewable energy required across the energy sectors (TEA)

18 Tipperary Energy Agency 2013 19 Irelands Greenhouse Gas Emission Projections – EPA 2012-2030

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The NREAP points to a range of policy actions required to achieve the outlined obligations. These are used as the basis for modeling the NREAP scenario; the key national recommendations for renewable energy generation to 2020 are set out below;

National Renewable Energy Generation Application Area

NREAP Policy

Electricity An expansion of biomass electricity-generating capacity to 270 MW through the implementation of co-firing plans in Edenderry power station (35 MW), the construction of two waste-to-energy units (44 MW), and the continued development of landfill-gas electricity generation (44 MW) and biomass CHP (150 MW). Construction of at least 75 MW of wave energy. An expansion of both onshore and offshore wind capacity, supported by the Gate 3 process, and the rollout of the transmission network upgrade plans.

Transport The Biofuels Obligation Act 2010 and the rollout of the Electric Vehicles (EVs) support measures, to help achieve the target of 10% of road vehicles being electric by 2020, and drive the renewable energy usage in transport. The biofuel obligation is designed so it can be adjusted upwards as required to meet the target.

Heat The recently approved REFIT tariffs for biomass CHP drive the use of renewable heat in industrial and commercial applications. Part L of the 2008 Building Regulations requires new residential buildings to install renewable heating technology.

Achievement of the strategic goals and delivery of the key actions for renewable energy will require a fully integrated cohesive approach across many Departments and Agencies, including the Commission for Energy Regulation, EirGrid, ESB Networks, the renewable energy sector and its representative organisations, the enterprise community, the research community, local authorities, consumers and local communities. Renewable energy and climate change policy also influences other policy areas including Agriculture, Transport, Environment and Climate Change, Local Government and Enterprise. Underpinning the Government’s energy and economic policy objectives are the following five national Strategic Goals reflecting the key dimensions of the renewable energy challenge to 2020.


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National Strategic Goal 1 Progressively more renewable electricity to be produced from onshore and offshore wind power for the domestic and export markets.

National Strategic Goal 2 Development of a sustainable bio-energy sector supporting renewable heat, transport and power generation.

National Strategic Goal 3 Green-growth through research and development of renewable technologies including the preparation for market of ocean energy technologies.

National Strategic Goal 4 Increase sustainable energy use in the transport sector through use of bio-fuels and electrification as alternatives to use of fossil fuels.

National Strategic Goal 5 Development of an intelligent, robust and cost efficient energy networks system.

Strategic Goal for South Tipperary

The Government clearly supports the development of the renewable energy sector at the national level. However, as individual renewable energy targets are not set out at the county level it is difficult to identify how much renewable power is to be generated in county Tipperary to meet targets in the key sectors of electricity, transport and heat. Each region in the country has different renewable energy resources and varying potentials for the development of energy and depends on an interlinked national power grid system and it may be for these reasons that strategic goals for renewable energy rather than local targets have been produced by the Department of Communications, Energy and Natural Resources. There are benefits including employment, energy self-sufficiency and financial returns associated at the local level with the development of the renewable energy industry. South Tipperary County Council acknowledges the strategic national goals set out above, and the preparation of this RES is considered to be an important step towards the county’s contribution with respect the development of a sustainable renewable energy sector and the subsequent reduction in dependency on fossil fuel as the primary source of energy in Tipperary. In addition to this, South Tipperary County Council also acknowledges the rich environmental, cultural and heritage assets of the county and will seek to balance new development with the protection of the important environmental assets of the county. Strategic Goal for South Tipperary: South Tipperary County Council will seek to support and facilitate the development of the renewable energy sector of the county in line with the Strategic goals set out by the Department of Communications, Energy and National Resources whilst balancing the need for new development with the protection of the environmental, cultural and heritage assets of the county.


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5.0 Assessment of Supports & Constraints for Renewable Energy Production

5.1 Infrastructure

The development of the renewable energy potential of South Tipperary is heavily dependent on available and planned local and national infrastructure. Key infrastructure for energy production includes the national electrical grid, the national gas network, the transportation system of the county, and services and utilities including water and waste water networks etc.

5.1.1 Electricity The two bodies responsible for the national electrical network are Eirgrid and ESB Networks. ESB Networks is licensed by the Commission for Energy Regulation (CER) as the owner of the transmission system and is responsible for carrying out the maintenance and construction of the system and manages grid connection for micro-level generators20

.

EirGrid is the independent electricity Transmission System Operator in Ireland and the Market Operator of the wholesale electricity trading system. Its role is to deliver connection, transmission and market services to electricity generators, suppliers and customers utilising the high voltage electricity system. EirGrid’s Grid Development Plan is set out in Grid 25 – a Strategy for the Development of Ireland’s Electricity Grid for a Sustainable and Competitive Future. Through this investment Eirgrid intend to undertake grid reinforcements to connect significant amounts of wind generation to the grid. GRID 25 has been informed by the findings of the All-Island Grid study which demonstrated the feasibility of at least 40% renewable electricity in the network by 2020 if the grid is developed in accordance with the proposals set out. To ensure future electrical power needs are met in the south and east of Ireland, EirGrid is investing an estimated €500 million in a new development called the Grid Link21

Project. The project consists of a new 400 kV overhead power line linking Leinster and Munster. The power line will link will connect Knockraha in Cork with Great Island in Wexford to Dunstown near Naas, Kildare. A route is to be selected after detailed assessment of constraints and after consultation with all stakeholders with an interest in the project. A planning application to An Bord Pleanála under the Strategic Infrastructure Act will occur in 2015 and it is envisaged that the powerline will be delivered by 2018 at the earliest. See Figure 17 below for details of the study area.

The delivery of the improvements outlined under Grid 25 will be vital to ensure the full take up of grid connection offers for renewable energy developments proposed. 20 Micro-Generation is currently defined by ESB Networks in their Conditions Governing Connection and Operation of Micro- Generation as a source of electrical energy with an equipment rating of: (1) Less than 25A – single phase connection to the house – this is equivalent to a maximum output of 5.75 kW, or (2) Less than 16A – 3 phase connection to house – this is equivalent to a maximum output of 11 kW 21 www.eirgridprojects.ie

http://www.eirgridprojects.ie/�


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Figure 18: Route corridor for GRIDLINK

Grid Connections

To help promote the use of renewable sources of energy, the CER facilitates the connection of large renewable generators to the electricity network including the development of a group processing approach to speed up such connections. Group processing of connection offers through the ‘Gate process’ for renewable generation takes a strategic approach to connection offer processing and was proposed by EirGrid - as the Transmission System Operator - and ESB Networks - as the Distribution System Operator - in 2004 and approved by the CER. Since December 2004 renewable generators wishing to connect to the transmission or distribution systems have been subject to group processing of connection applications through a series of successive “Gates”. Gate 3 was the third renewable group processing directive proposed by the CER, this is now closed to offers. The 94 offers issued by EirGrid under the Gate 3 Programme represent a total of over 5,400 MW of electricity from renewable and conventional generators, this will represent more than Ireland’s peak demand load when all generators are operational. The CER will manage grid connection policy post GATE 3; vital to this will be take-up of Gate 3 grid connection offers, progress towards Grid 25 and volume of network connection offers. For further detail on Gate 3, post Gate 3 and grid connection offers refer to www.cer.ie – Fact sheet on Generator Connection Policy. The connection of micro-generators to the national electrical grid is not subject to the Gate process, for further detail on connection of micro generators refer to ESB networks publication – ‘Conditions governing the connection and operation of micro-generation’.

http://www.cer.ie/�


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5.1.2 Gas South Tipperary is supplied by the natural gas network in the towns of Carrick-on-Suir, Clonmel, Cashel and Cahir. Gaslink is the operator of the gas transportation system in Ireland. Gaslink’s view is that future energy policy should be based on a strategy which combines natural gas with gas sourced from renewable resources. Gas is a good partner to wind energy and other renewables as it provides the ideal back-up to counteract the intermittent nature of some renewable energy sources, particularly wind. In 2010 Bord Gáis in association with UCC and Ernst & Young, produced a report 'The Future of Renewable Gas in Ireland' which outlines how grass and waste can be converted into natural gas that can then be used locally or piped into the national grid for distribution around Ireland. The report estimates that 7.5% of Ireland’s gas demand could be met by renewable gas, the equivalent of heating 300,000 homes each year. The report sets out 6 key recommendations to assist in the production of bio-methane suitable for distribution by the national gas network in Ireland;

• Set targets for gas demand to be met with bio-methane, • Government to review REFIT tariffs provided for anaerobic digestion, • Implement new energy regulations to encourage bio-methane injection into the grid, • Align renewable energy and waste management policy, • Implement new support structures for agriculture, and, • Additional research and development funding for renewable gas technologies.

5.1.3 Transportation South Tipperary is well serviced by the national roads network and it is also serviced by the single line rail service through the towns of Carrick-on-Suir, Clonmel, Cahir, Tipperary Town and Limerick Junction. The M8 Dublin to Cork motorway traverses the county in a north to south direction whilst the N24 from Limerick to Waterford Cities transverses the county in a west to east direction. The M8, the N24 and the rail line all intersect at Cahir town ensuring that this location is strategic in the south east from a locational and accessibility perspective. It is vital that the strategic route networks in the county (National and Regional Roads provide an efficient method of transportation with direct links to and between the gateways, ports and airports outside the county linking the major towns within the county. The ability of users (and goods) to get to their destination safely and efficiently will require that the carrying capacity of the strategic route networks is protected and enhanced as identified in the County Development Plan. In assessing applications for development on national routes outside areas where a 50kph speed limit applies, the Council will seek the recommendation of the National Roads Authority and have regard to the Department of the Environment, Community and Local Government - Spatial Planning and National roads Guidelines for Planning Authorities, 2012.


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5.1.4 Services and Utilities The County Development Plan outlines the extent of services and utilities provided in the county. Such facilities include for the potable water supply network, water abstraction points, the wastewater treatment plant network and surface water control networks in urban areas. For further details on services and utilities in the county refer to the County Development Plan at www.southtippcoco.ie.

5.1.5 Telecommunications and Aviation The development of renewable energy resources has a low level of potential impact on telecommunications infrastructure and aviation routes in South Tipperary. The greatest potential for impacts occurs with commercial development of wind turbines. In assessing planning applications for wind energy developments the council will have regard to input from the Irish aviation authority and the Commission for Communication Regulation.

5.2 Environmental and other constraints

5.2.1 Natural Heritage The Environmental Report that accompanies this RES identifies the range of natural heritage assets in the county. Many of these are designated through European legislation and others of local significance are designated in the County Development Plan. The key natural heritage assets are set out below:

Special Areas of Conservation (SAC’s) and Special Protection Areas

SACs are prime wildlife conservation areas in the country, considered to be important on a European as well as Irish level. The legal basis on which SACs are selected and designated is the EU Habitats Directive (92/43/EEC), transposed into Irish law in the European Union (Natural Habitats) Regulations, 1997. SPAs were designated under the EU Birds Directive 79/409/EEC order to safeguard certain habitats. SEAs and SPCs together are designated as Natura 2000 sites. The RES is subject to Appropriate Assessment (AA) under the Habitats Directive to address the protection of Natura 2000 sites; and the Natura Impact Assessment is set out in Volume 2. AA is a focused and detailed impact assessment of the implementation of the plan or project alone or in combination with other plans and projects, on the integrity of a Natura 2000 site in view of its conservation objectives. The AA process has determined that the RES will not have an adverse impact on Natura 2000 sites. However, all renewable energy projects proposed will individually be subject to the requirements of the Birds and Habitats Directive and through the AA process will be required to demonstrate that they will not have an adverse impact on Natura 2000 sites before they will be permitted to proceed. In this respect AA screening will be carried for all renewable energy projects and to support this process Natura Impact Statements (NIS) should be submitted with planning applications for new development.

Natural Heritage Areas

There are a significant number of sites located within the county designated as proposed Natural Heritage Areas (pNHA’s) (to be protected in accordance with the Wildlife Act 2000) along with one NHA already formally protected (Slievenamon Bog). These are areas

http://www.southtippcoco.ie/�


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considered important for the habitats present or which holds species of plants and animals whose habitat needs protection. In South Tipperary these comprise a wide variety of habitats with a broad geographical distribution across the county, including woods, ponds, marshes bogs etc. Designated sites are identified in the South Tipperary County Development Plan. Before a decision is made to permit any proposed renewable energy project to proceed it must be demonstrated to the satisfaction of the planning authority that the project along or in combination with other projects will not have an adverse impact on any NHA or pNHA.

5.2.2 Landscape and Visual Amenity The protection of the landscape and character of the county, whilst also supporting the ability of the county to produce energy locally is an important concern of the RES. The RES itself has been informed by the county Landscape Character Assessment (LCA) and the SEA prepared as part of the preparation of the RES. Certain aspects of the renewable energy production industry including commercial wind turbines, processing facilities, renewable energy cropping have the potential to impact on landscape character over both the short and long term. In view of the size and scale of commercial wind farms, the South Tipperary Wind Energy policy has designated areas where commercial wind turbines will not be permitted due to the sensitivity of the landscape. Please refer to Appendix 3 for details of wind energy areas.

5.2.3 Archaeological and Architectural South Tipperary is endowed with a wealth of archaeological and architectural assets including sites and monuments and protected structures. Details of these assets are outlined in the SEA accompanying this RES. Proposals for new renewable energy developments should be mindful of the rich architectural and historical heritage of the County. For further detail on environmental constraints please refer to the Environmental Report and NIA that accompanies this Draft RES and set out in Volume 2.

5.2.4 Aquatic Environment This RES is also concerned with the protection of the aquatic environment in general and the Council will seek to ensure that any proposed projects will not conflict with the requirements of the Water Framework Directive and the requirement to maintain existing good or high ecological status waters and to improve other waters to at least good status. The status of water bodies that are designated as salmonid waters and water bodies that are an ecosystem for the freshwater pearl mussel are of particular importance in South Tipperary. All renewable energy projects proposed will be subject to the requirements of the Birds and Habitats Directive and the AA screening process will be applied to ensure that projects will not have an adverse impact on Natura 2000 sites.


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6.0 Renewable Energy Benefits & Supports 6.1 Economic benefits of RE production

In 2012 the Government published an ‘Action Plan for Jobs’ strategy which outlined the national employment growth potential of the renewable energy sector. The report acknowledges that renewable energy, smart grid development, energy efficiency products and services are key sub sectors of the green economy. It identifies that the global clean technology market has been estimated at €3.5 trillion with the potential to grow by more than 4% per annum to 2015. The Expert Group on Future Skills Needs (EGFSN) indicated that there were 19,000 people employed directly in Ireland in 2010 in the key sub sectors of the green economy referenced above (excluding agri food production). It suggested that up to an additional 10,000 jobs could be created across the variety of sub sectors listed above by 2015 through the adoption of appropriate policies. The longer term job creation potential is even more significant, particularly in the area of renewable energy. For South Tipperary, TEA has highlighted the employment potential of the renewable energy sector. At present, due to the reliance on imported fuels in the county rather than the use of locally produced renewable resources, employment generation from renewable energy production is low. However, there is potential employment in renewable energy production associated with the manufacture of products and the construction and installation phase, with the other important area being the operations and maintenance of plants and systems. From a long term perspective the operation and maintenance of renewable energy facilities offers the greatest potential for employment to the county. TEA has calculated that anaerobic digestion offers the greatest employment opportunity. Biomass will also have a big impact as the operation and maintenance phase is more labour intensive than the construction and installation phase, this coupled with the of biomass resource within the south east region gives it a high employment potential in South Tipperary. Biomass processing has a high employment potential within South Tipperary given that there still is a very low uptake. Having consideration to the employment benefits the potential of biomass as a renewable energy production resource should be recognised, not only to help reach energy targets but also to contribute to local and regional employment rates.

6.2 Renewable Energy Types and Technologies

The SEAI ‘Methodology for Local Authority Renewable Energy Strategies’ describes the main renewable energy types and technologies likely to be developed in Ireland. Also set out are the key planning considerations for local authorities in assessing planning applications for the various developments associated with the production of renewable energy22

22 SEAI Methodology for Local Authority Renewable Energy Strategies, Chapter 2 and Appendix A.4.

. This is a useful reference for planning officials, members of the public and developers alike.


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Some renewable energy technologies are in early stages of development and others are continually being improved from a technological and efficiency perspective. In this respect, it is acknowledged that in assessing planning applications for renewable energy developments, it will be necessary to support and consider new technologies and changes to existing energy installations in respect of their operation and scale where it is adequately demonstrated that they will not adversely impact on human health or the environment and where it is demonstrated that they can be operated to the requirements of best practice guidelines and Section 28 Planning Guidelines as appropriate.

6.3 Renewable Energy Support Schemes

There is a number of support schemes designed to support the development of renewable energy. More information on these can be found in the National Renewable Energy Action Plan.23

Support schemes for renewable energy will vary and be subject to change over time and developers should contact the SEAI for details of current support schemes.

In the electricity sector, the main support scheme is the REFIT scheme. REFIT the 'Renewable Energy Feed in Tariff' is the primary means through which electricity from renewable sources is supported in Ireland. The first REFIT scheme ('REFIT 1') was announced in 2006 and state aid approval was obtained in September 2007. The REFIT 1 scheme was open for applications until the end of December 2009 and since that date no new applications have been accepted under the scheme. The REFIT 2 scheme (onshore wind, small hydro and landfill gas) was opened in March 2012 and the REFIT 3 (biomass technologies) scheme opened in February 2012. Both schemes support projects built and operational between 01 January 2010 and 31 December 2015. In the biomass sector, the Department of Agriculture, Food and the Marine, operates a Bioenergy Scheme to grant aid the planting of willow and miscanthus crops and these Schemes have supported the planting of over 3,000 hectares of energy crops since 2007. The scheme aims to increase the production of willow and miscanthus in Ireland and to encourage alternative land options, for further details please refer to the Department of Agriculture, Food and the Marine Website at www.agriculture.gov.ie. Other support schemes are available (as mentioned above), such as the prototype development fund of grants for the wave and tidal sector. In the transport sector, the Biofuel Obligation Scheme requires specified volumes of biofuels to be incorporated in petrol and diesel. A consequence of this obligation is that developers may be motivated to produce biofuels as they know that biofuels are required by suppliers to meet their obligation. The Department of Agriculture runs an energy crop scheme, providing grants for the production of energy crops. Grants are also available for electric vehicles.24

23 www.dcenr.gov.ie/ 24 www.seai.ie/Grants/Electric_Vehicle_Grant_Scheme/EV_Grants/

http://www.agriculture.gov.ie/�

http://www.dcenr.gov.ie/Energy/Sustainable+and+Renewable+Energy+Division/Renewable+Energy+Directive+and+National+Renewable+Energy+Action+Plan.htm�

http://www.seai.ie/Grants/Electric_Vehicle_Grant_Scheme/EV_Grants/�


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The heat sector is supported indirectly through REFIT for biomass technologies. While REFIT is only payable on metered electricity exported, a number of biomass technologies also support renewable heat production; e.g. biomass high-efficiency CHP. The SEAI Better Energy Programme of grants for households also supports solar thermal energy.25

There are a number of government tax relief schemes such as the Employment and Investment Incentive, section 486b of the Tax Consolidation Act, and the Accelerated Capital Allowance scheme that can be of direct and indirect use in supporting RE development. A good reference for details of current and up-to date renewable energy support schemes and their status can be found under the Department of Communications, Energy and Natural Resources – NREAP Progress Reports. As schemes are constantly changing over time, reference should be made to the Department of Communications, Energy and Natural Resources, the SEAI and to TEA to ascertain the status of grant schemes and supports in place for renewable energy production. Further details for all of the current support schemes are available online at www.decnr.gov.ie

6.4 Renewable Energy Projects and Local Community Involvement

Renewable energy developments and especially large scale wind energy developments can give rise to community concern that a new development will have a negative impact on an area. The typical concerns raised revolve around fear that a new development will have a visual impact on an area, result in noise or heavy traffic, create emissions or shadow flicker, have an impact on animals and water quality etc. Local communities may feel disconnected from the planning process and feel real community involvement does not occur. In the case of large scale developments such concerns are understandable particularly where community involvement in the planning and development process from the outset is poor. This section sets out to identify the process of community involvement in the planning and development process itself and the opportunities for more meaningful community involvement in renewable energy development.

6.4.1 Planning and Development Exemptions Certain micro-renewable generation installations for domestic, agricultural and light industrial activities are now exempted development subject to criteria detailed in the Planning and Development Regulations (Statutory Instrument No. 83 of 2007, No. 235 of 2008 and No. 256 of 2008). In a case where an individual wishes to erect a small-scale renewable energy generation system that comes within the exemption limits, public consultation is not required. Information in relation to exempted development is available by downloading the above referenced statutory instruments from the Department of the Environment, Community and Local Government’s web site, or by contacting the South Tipperary County Council Planning Department.

25 www.seai.ie/Grants/Better_energy_homes/Better_Energy_FAQ/

http://www.decnr.gov.ie/�

http://www.seai.ie/Grants/Better_energy_homes/Better_Energy_FAQ/�


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6.4.2 Planning Application and Community Consultation All Development of land or property requires Planning Permission unless it is exempted development under the Planning and Development Acts 2000-2012 and Planning and Development Regulations 2001-2012. Renewable energy development that is not exempted development therefore will require planning permission from South Tipperary County Council. Public consultation for any planning application in respect of renewable energy development must comply with the requirements of the Planning and Development Regulations 2001-2012 in respect to third party participation i.e. a site notice and newspaper notice will be required, public submissions will be invited and a third party right to appeal to An Bord Pleanála will apply. There is no statutory requirement for a developer to consult with the local community in respect any proposal for a large scale renewable energy development over and above the statutory requirements set out in the Planning and Development Acts. However, the Wind Energy Guidelines 2006 recommend that the developer of a wind energy project should engage in active consultation and dialogue with the local community at an early stage in the planning process, ideally prior to submitting a planning application. Further detailed guidance on community involvement is described in the Irish Wind Energy Association (IWEA) Best Practice Guidelines for Wind Energy Development 2012. It is stated in these Guidelines that; ‘A well considered and executed community engagement plan will improve the likelihood of community acceptance of the project. The corollary is that poor or non-existent community engagement can increase the likelihood of negative reactions resulting in increased opposition to the development and greater planning risk’ In this respect South Tipperary County Council will at pre-planning consultations advise all developers of renewable energy projects to undertake community consultation in line with the IWEA Best Practice guidelines.

6.4.3 Strategic Infrastructure Strategic infrastructure development is development which is of national strategic economic or social importance. It also includes development which will contribute significantly to the fulfilment of any of the objectives of the National Spatial Strategy or any Regional Planning Guidelines for an area, or which would have significant effects on the area of more than one planning authority. Qualifying developments are listed in the Seventh Schedule of the Planning and Development Acts 2000-2012 and a planning application in respect of such developments will be made directly to An Bord Pleanála rather than to the planning authority. In such cases the Local Authority prepares a planning report with recommendations to An Bord Pleanála identifying the Local Authority opinion with respect the Strategic Infrastructure application for the consideration of An Bord Pleanála. In this respect, certain large scale renewable energy developments may come under this category. Planning applications to An Bord Pleanála for strategic infrastructure must be accompanied by an Environmental Impact Assessment and the publication of a public notice. Public submissions will be invited and these will be considered by An Bord Pleanála when making


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their decision. In addition to the acceptance of public submissions, An Bord Pleanála may also accept recommendations from the Elected Members of the Council. An Bord Pleanála may apply the standard planning conditions to any grant of planning permission for Strategic Infrastructure, however, it should be noted that An Bord Pleanála is also empowered to attach a condition obliging the developer to provide a planning or community gain in the form of a ‘facility or service’ which would constitute a community gain for the local area. This power was applied to the grant of planning permission for the Aviva Stadium in Dublin 26

. Condition Number 22 specified that a Project Monitoring Committee be established with representatives from the developer, the local community and the local authority. This Committee is to receive €75,000 per annum to be used for environmental maintenance and improvement in the area and for social and educational activities benefitting the local community.

In the Government Policy Statement on the ‘Strategic Importance of Transmission and Other Energy Infrastructure’27

dated 17th July, 2012, the Department of Communications, Energy and Natural Resources confirmed the Government’s commitment to transparent community participation and information along with the appropriate community gain in Strategic Infrastructure Developments. It was stated in this document:

‘The Government underlines the imperative for the State Companies, and all developers of energy projects, of early, transparent engagement and consultation with local communities and stakeholder and the appropriateness of building community gain consideration into project planning and budgeting and as an intrinsic part of the ongoing consultation with local communities and local authorities’.

6.4.4 Community Gain and Renewable Energy Development There are a number of different models for local community engagement in renewable energy development which involve varying degrees of impact and risk and different ways of defining communities/distributing benefits. In Ireland, the concept of community involvement in renewable energy development is underutilised when compared with Scotland where a dedicated body - ‘Community Energy Scotland’ provide guidance and advice to communities on how they may become involved and benefit from local community energy. A detailed guidance document entitled ‘Community Renewable Energy Toolkit’ was published in 201128

and is a practical guide on how communities can be involved in renewable energy.

It is for each community to decide which model best suits their needs, and there may particularly be a case for different modes of engagement and different solutions in rural and urban areas.

26 An Bord Pleanála Plan Reference 218917, Lansdowne Road stadium Development Ltd 27 www.dcenr.ie 28 Commissioned by the Scottish Government and Energy Saving Trust Produced by Community Energy Scotland Limited

http://www.dcenr.ie/�


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Examples of models include: 100% ownership of a renewable energy development by the community group i.e. the Templederry Community Wind farm29, voluntary community fund made by the commercial developer i.e. Airtricity Community fund30, or joint ventures or mixed ownership via a community body or co-operatives i.e. the District Heating system, owned and run by the not-for-profit Cloughjordan Ecovillage Service Company31

Community funds are increasingly being proposed on a voluntary basis by large scale wind energy developments as a means to involve the local community and to give something back to the local area. The Airtricity Community Fund is an example and is intended to support community projects in the locality of commercial wind farms. The Airtricity fund is distributed on an annual basis for the lifetime of the wind farm, starting one year after the wind farm is commissioned. Local community applications for funding are invited each year and the quantity of the fund may vary slightly year on year depending on the electricity produced by the wind farm. The fund will be used to support local community activities with a focus on energy efficiency and sustainability.

.

The Airtricity Community Fund Applications are evaluated on a competitive basis with a strong preference on energy efficiency and sustainability projects and are adjudicated based on how the project best fits with the Airtricity company values set out below:

• Energy Efficiency • Sustainability • Teamwork/Community • Service • Excellence • Safety

As stated above the development of large renewable energy projects can also help the local economy as a result of local firms gaining work during construction, local businesses and accommodation benefitting from construction teams in the locality and a local maintenance crew being established. It should be recognised also that commercial wind developments usually result in the site landowners gaining some form of rental payments, which can be re-invested in their local businesses and subsequently back into the local economy. South Tipperary County Council is very supportive of active community involvement in renewable energy schemes and encourages local communities and renewable energy developers to liaise with the TEA to investigate opportunities for community involvement. 29 Templederry Community Group and Tipperary Energy Agency 30 www.airtricity.ie 31 www.thevillage.ie

http://www.airtricity.ie/�

http://www.thevillage.ie/�


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7.0 County Renewable Energy Strategy It is envisaged that there will be significant investment in the renewable energy industry. National level investments include the 400Kv GRIDLINK project, the proposal for export of power generated from wind from the Midlands to Britain and Europe etc. It is expected that investment in renewable energy projects will increase and this will translate into greater numbers of planning applications to the Planning Authority and installation of micro-level renewable energy installations as exempted development. This will result in a challenge for the council to ensure that a balance is achieved between growth in the renewable energy industry and the protection of the community and environmental assets of the county. This RES has examined renewable energy potential and demands in South Tipperary along with national goals as set out in the Strategy for Renewable Energy 2012-2020. It considers the contribution that South Tipperary can make to the national energy targets by way of increased renewable energy production. Consideration was also given to local and community benefits that will arise as a result of the development of renewable energy resources. Finally, the development of renewable energy has been considered in the context of the environmental and social well-being of the county and its communities. This RES has identified a vision for growth for renewable energy development for South Tipperary based on its real renewable energy potential. Based on this a planning policy framework to guide development has been proposed. This planning policy will underpin the statutory planning and development policy of the County Development Plan.

7.1 Vision for Growth

The Department of Communications, Energy and Natural Resources NREAP sets out the Irish Government’s strategic approach to deliver on Ireland’s target of 16% of the national gross final consumption of energy comprising energy from renewable sources by 2020 (under Directive 2009/28/EC). The Government plans that by 2020 the overall binding target will be delivered by approximately:

• 40% consumption from renewable sources in the electricity sector (RES-E), • 12% in the heat sector (RES-H), • 10% in transport (RES-T).

South Tipperary County Council has prepared this RES to underpin its commitment to the achievement of the renewable energy targets set out in the NREAP at the county level. It recognises the key renewable energy resources of the county and the benefits that will arise from the sustainable development of these resources. It is the goal of the Council to support and facilitate the development of the renewable energy sector of the county in line with the Strategic goals set out by the Department of Communications, Energy and National Resources whilst balancing the need for new development with the protection of the environmental, cultural and heritage assets of the county.


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7.2 Renewable Energy Strategic Targets

The following key strategic targets have been proposed and the County Council with the TEA will endeavor to implement and achieve these key targets over the lifetime of this RES. It is proposed to merge South and North Tipperary County Council in 2014 and this will involve the preparation of a joint county development plan in due course, renewable energy planning policy may be reviewed at this time to address the development of renewable energy for the entire county. Forthcoming regional reform must also be considered; the current eight regional authorities and two regional assemblies will cease to exist and will be replaced by three regional assemblies and the entire county of Tipperary will be located in a single regional assembly for the south of Ireland. The new Tipperary County Council and TEA will seek to liaise with the South East Regional Authority and thereafter the southern regional assembly in respect the achievement of the key targets set out below. No. Strategic Target Responsibility Timeframe 1. Actively liaise with the Tipperary

Energy Agency to jointly promote and facilitate renewable energy production in the county.

The County Council and Tipperary Energy Agency

Ongoing

2. Produce a Renewable Energy Strategy for South Tipperary after consultation with stakeholders.

The County Council and TEA

2014

3. Develop and Incorporate policy and objectives for renewable energy production in the county into statutory planning policy.

The County Council At the next review of the Tipperary County Development Plan

4. Prepare a county energy balance for Tipperary every 2 years.

Tipperary Energy Agency

2014 (after merger)

5. Carry out an analysis (every two years) of the main barriers to the development of renewable energy in Ireland in conjunction with consultation with the key stakeholders in the area.


2014 (after merger)

6. Carry out a review of this RES in 2020 to assess the success of renewable energy production in the county and amend planning policy if necessary.

The County Council and Tipperary Energy Agency

2020

7. Produce a bioenergy inventory of the County and make available on-line to assist producers of bioenergy. This


2016


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shall be updated every two years. 8. Facilitate National Renewable Energy

Policy and Support Schemes at the County Level through the Planning and Development Process.

County Council and Tipperary Energy Agency

Ongoing

9. Set up a joint progress group to stimulate growth, and develop appropriate policy for the areas of Renewable energy, Energy Efficiency and Climate Change Adaption.


2014

10.

Support the implementation of Part L of the Building Regulations.

County Council Ongoing

11. Tipperary Local Authorities to continue act as leaders in the promotion and use of Renewable Energy across the organisation and in the delivery of its services.


Ongoing

Figure 19: Wood Pellet manufacturing plant


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7.3 Policy Development

Having consideration to the growth areas for renewable energy identified for South Tipperary, the infrastructural supports and constraints to renewable energy production as outlined in Section 5.1 and the strategic policy of the County Development Plan with respect the support and development of the renewable energy industry in the county, planning policy to guide and inform development proposals is set out below:

7.3.1 Protection of the Environment Planning applications for new development will be required to establish that development will not give rise to an adverse impact on environment. It is recommended that the following environmental policy be incorporated into statutory planning policy to ensure the protection of the environment and designated sites:

• It is the policy of the Council to require an Environmental Impact Assessment (EIA) for new development where it meets the thresholds specified in Schedule 5 of the Planning and Development Regulations 2001 - 2012. An Environmental Impact Assessment (EIA) shall include an assessment of the likely impacts arising from the development on protected flora and fauna, in this respect planning applicants should refer to ‘The Guidelines for Planning Authorities and An Bord Pleanála on carrying out EIA’, Department of Environment, Community and Local Government 201332

. An EIA shall also accompany an application for sub-threshold developments where the Planning Authority is of the opinion that the potential environmental impact is such that an EIA is warranted, in this respect applicants should consult the ‘Environmental Impact Assessment (EIA) - Guidance for Consent Authorities regarding Sub-threshold Development’, published by the Department of Environment, Heritage and Local Government, 2003.

• It is a policy of the Council to conserve and protect the ecological integrity of designated sites of international and national importance, and sites proposed for designation, in particular, European sites (including Natura 2000 sites), and Ramsar sites, NHAs and statutory nature reserves.

• Where a proposed renewable energy related development has the potential for

significant impacts on Natura 2000 sites (either individually or in combination with other plans or projects), it is a policy of the Council to require the submission of a Natura Impact Assessment (NIS) at planning application stage to enable the planning authority carry out Appropriate Assessment (AA) of the proposed development. If it can be concluded on the basis of AA that there will be no adverse effects on the integrity of a Natura 2000 site, the project can proceed to authorisation, where the normal planning or other requirements will apply in reaching a decision to approve or refuse planning permission. If adverse effects are likely, or in cases of doubt, the derogation steps of Article 6(4) of the Habitats Directive will apply, but only in a case in which there are imperative reasons of overriding public interest (IROPI) requiring a project to

32 www.environ.ie



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proceed, there are no less damaging alternative solutions, and compensatory measures have been identified that can be put in place.

7.3.2 Wind

Commercial wind farms and individual on-site large turbines The South Tipperary Wind Energy Strategy was incorporated into planning policy as part of the County Development Plan in 2006. The Wind Energy Strategy has provided for the sustainable development of the county wind energy resources since its adoption and it is considered that the current wind energy areas as identified in the wind energy strategy should be maintained until the next review of renewable energy planning policy for the entire county. The county wind energy development areas are set out in Appendix 3. It is furthermore recommended that the following policy approach to wind energy development should be incorporated into the County Development Plan in support of the current wind energy policy:

• In applying the Wind Energy policy of the County Development Plan, the Council will actively encourage developers and investors to engage with local communities to ascertain their concerns with respect new development, to undertake to address these concerns where feasible and to consider the setting up of appropriate community funds or schemes that will help to confer a gain to the local community in areas where it is proposed to install large-scale renewable energy developments.

• In applying the Wind Energy policy of the County Development Plan, the Council will

actively encourage developers and investors to consider the cumulative impact of wind energy development in areas where wind developments have already been permitted. Reference in this respect may be made to the Wind Energy Guidelines 2006 and to the Scottish Natural Heritage Guidelines – ‘Assessing the Cumulative Impact of on-Shore Wind Energy Developments 2012’.

• In applying the Wind Energy Policy of the County Development Plan, the Council will ensure the protection of the environment and apply the minimum environmental protection standards as set out in Section 7.3.1 above.

Micro-Generation Conditional planning exemptions incorporated into the Planning and Development Regulations 2001-2012 (SI 83 of 2007 and SI 235 of 2008) provide for renewable energy technologies including wind turbines that meet specified criteria. The purpose of these planning exemptions was to help stimulate and encourage uptake of renewable energy technologies at a small scale and reduce energy costs to individual users. Where micro-generators are above the thresholds for exempted development but still considered to be of a small scale*, the normal planning process and provisions of the Wind Energy Strategy will apply. The Council will seek to balance the protection of the landscape and residential amenity with the potential for the production of renewable energy from micro wind generators.


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*In line with REFIT 2 a small scale wind project means any wind-powered electricity generating scheme with a maximum export capacity of 5 MW or less which is connected directly to the electricity network and metered independently of any other electricity generating plant.

7.3.3 Biomass The ‘South East Bio-Energy Implementation Plan for the South East’ as reviewed in 2013 sets out the regional vision for the production of energy from biomass sources to 2020. The Council will support the targets set out in this Implementation Plan through its own County Development Plan. REFIT 3 was introduced in 2012 to incentivise the addition of 310MW of renewable electricity capacity to the Irish grid through Biomass technologies. Of this, 150MW will be High Efficiency CHP (HE CHP), using both Anaerobic Digestion and the thermo-chemical conversion of solid biomass, while 160MW will be reserved for biomass combustion and biomass co-firing. In line with the government support for biomass through REFIT 3, the Council will seek to balance the protection of the environment with the potential for the production of renewable energy from biomass resources. The Council will assess such proposals based on the considerations set out below and will apply the minimum environmental standards as set out in Section 7.3.1 Protection of the Environment where appropriate:

Large-Scale Large scale commercial bio-energy processing facilities which depend on imported feedstocks will be assessed on a case-by-case basis and will be subject to a planning assessment that will consider matters such as the ability of the receiving environment to accommodate the development without adverse environmental impact. Important considerations will be impact on traffic infrastructure, impact on the environment, availability of supporting public infrastructure. Such facilities should be suitability located in line with the strategic employment policy of the County Development Plan or subject to the scale of the proposal located on suitably zoned land located within urban areas. Such facilities are considered to be of a regional scale based on the extent of their feedstock supply area. In this respect the Council will consider regional planning guidelines (in force at the time) including the South East Regional Planning Guidelines 2010 and the Waste Management Plan for the South East in assessing any planning application.

Medium Scale It is envisaged that medium scale bio-energy processing facilities will play a key role in the production of renewable energy in the county, such facilities generally utilise feedstock produced on site, sometimes supported by an ancillary percentage of imported feedstock. Bio-energy facilities using agricultural waste products as a feedstock are very compatible with farm operations in the county and their development will be encouraged on farm sites. Bioenergy proposed from medium scale CHP facilities using wood fuels, agricultural waste or energy crops and developed on site with commercial enterprises will contribute to the local economy by making creating employment and reducing dependency on imported energy. Such proposals will be assessed on a case by case basis in line with normal planning


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and development control standards and based on the ability of the receiving environment to accommodate the development without adverse impact.

Small scale/Micro-Generation Bioenergy produced at the small scale may include anaerobic digestion on-farm using materials produced onsite or biomass boilers associated with commercial/industrial facilities that either produces biomass on site or imported material and where energy is used on site. Small-scale wood pellet boilers and stoves have been classed as exempted developments subject to restrictions; this is to incentivise the installation of such facilities. In line with this approach, the Council will take a proactive approach to the installation of renewable energy biomass technologies at a small scale. Where an individual wishes to install micro-renewable technology that does not fall within the planning exemptions as it is, for example, over the size thresholds an application may be made for planning permission. Such proposals will be encouraged and facilitated and assessed on their own merits in line with normal planning and development control standards.

7.3.4 Hydropower The REFIT 2 scheme currently supports small scale33

hydro power generation. In line with government support for small scale hydropower development, the Council will seek to balance the protection of the aquatic environment with the potential for the production of renewable energy from the installation of hydro power schemes at a small scale subject to it being demonstrated that they will not have an adverse impact on designated sites.

The Council will apply Inland Fisheries Irelands’ best practice guidelines – Guidelines on the Construction and Operation of Small-Scale Hydroelectric Schemes and Fisheries 2005 and any review thereof, in assessing planning applications for new hydropower facilities. The Council will also seek to ensure that any proposed projects will not conflict with the requirements of the Water Framework Directive and the requirement to maintain existing good or high ecological status waters and to improve other waters to at least good status. All proposed hydropower projects will be required to demonstrate that the aquatic environment will not be adversely affected and proposed projects should ensure that they do not conflict with the following key principles as they apply to the aquatic environment:

• Maintenance of water quality at all times with view to improving status to ‘good quality’ for all watercourses.

• Consideration of surface water hydrology and flood risk prevention. • Identification of and protection of adult fish habitats, spawning grounds and nursery

areas. • Passage of all migratory fish species and the maintenance of necessary flow regimes

in rivers and streams to maintain aquatic life and diversity.

33 "hydro" and "hydro project" means any hydro-powered electricity generating plant with a maximum export capacity of or less than 5 MW which is connected directly to the electricity network and metered independently of any other electricity generating plant.


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• Maintenance of biological diversity in watercourses and in associated riparian zones and wetland areas and protection of ecosystem structure and functioning.

• Management and control of invasive species. Proposals for larger scale hydro power schemes (greater than 5MW), including PHES will be assessed on a case by case basis and will be subject to a planning assessment that will consider matters such as the ability of the receiving environment to accommodate the development without adverse environmental impact. The Council will apply the minimum environmental standards as set out in Section 7.3.1 Protection of the Environment to proposals for hydropower generation where appropriate.

7.3.5 Solar (solar thermal or solar electric) Certain solar harvesting systems have been classed as exempted developments subject to restrictions; this was to incentivize the installation of such facilities. In line with this approach, the Council will take a proactive approach to the installation of solar technologies at a small scale. Where an individual wishes to install solar energy technology that does not fall within the planning exemptions as it is, for example, over the size thresholds or where it would alter the character of a protected structure or streetscape an application may be made for planning permission. Such proposals will be encouraged and facilitated and assessed on their own merits in line with normal planning and development control standards. However, it should be noted that care will be required in respect of such technology proposed in architectural conservation areas or protected structures in view of the potential to materially alter the visual character of structures or places. The Council will apply the minimum environmental standards as set out in Section 7.3.1. Protection of the Environment to proposals for solarpower generation where appropriate

7.3.6 Geo- thermal Certain ground source heat pump systems (agricultural and industrial only) have been classed as exempted developments subject to restrictions; this was to incentivise the installation of such facilities. In line with this approach, the Council will take a proactive approach to the installation of geothermal technologies at a small scale. Where an individual wishes to install a heat pump systems that does not fall within the planning exemptions as it is, for example, over the size thresholds or associated with a domestic dwelling an application may be made for planning permission. Such proposals will be encouraged and facilitated and assessed on their own merits in line with normal planning and development control standards. The Council will apply the minimum environmental standards as set out in Section 7.3.1 Protection of the Environment to proposals for geothermal power generation where appropriate.


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7.4 Monitoring

Individual targets for renewable energy production have been set at the national level only; individual county level targets have not been outlined. It is possible however, to assess energy consumption in the county under the key consumers of electricity, heat and transport and to consider the consumption of energy in the county against national targets. The TEA regularly prepares an energy balance for the county and can determine the success with achieved in increasing renewable energy production. It is proposed that a county energy balance be prepared every two years until 2020 and thereafter to monitor county renewable energy production. A key indicator of success in the promotion and planning for renewable energy production and development will be the assessment of the county energy balance, however, the implementation of this RES will also be readily measured by assessment of how successfully the targets set out in Section 7.2 have been achieved over the lifetime of the strategy.


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Appendices


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Appendix 1 Department of Communications, Energy and Natural

Resources - Strategy for Renewable Energy 2012-2020 Strategic Goals.

Strategic Goal 1: Progressively more renewable electricity from onshore and offshore wind power for the domestic and export markets. Key Actions:

• Support delivery of the 40% target for renewable electricity through the existing GATE processes. A further targeted Gate may be developed, if necessary, following a review of the take-up of Gate 3 offers. While developing a next phase plan led approach for additional onshore capacity in future;

• Work to overcome the existing obstacles and delays in the GATE processes including

the environmental and permitting and any emerging regulatory barriers;

• Review with the Department of Environment and CER the scope for further streamlining authorisation and planning processes for renewable energy projects.

• Take forward the Local Authority Renewable Energy Strategies template being

developed by SEAI through working with and local authorities to assist in developing Local Authority Renewable Energy Strategies for renewable energy development commensurate with spatial planning and environmental needs;

• SEAI to complete and publish a fully updated National Wind Atlas in 2012;

Implement REFIT 2 for onshore renewable energy and maintain a predictable and transparent REFIT support framework for onshore wind which is cost competitive. REFIT (Renewable Energy Feed in Tariff) is a feedin- tariff support scheme for new renewable generation. The original scheme

• (REFIT 1) was put in place to ensure delivery of our 2010 renewable electricity target, a goal in which it was successful.

• Following on from this, REFIT 2 is designed to accommodate new renewable

generation built to the end of 2015 and its aim is to ensure sufficient new renewable electricity is built to make a significant contribution to our legally binding 2020 target under Directive 2009/28/EC.


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• Ensure that the regulatory environment for renewable energy projects in the electricity market is appropriate , predictable and in line with EU requirements, having regard also for the needs of conventional generation;

• As we progressively move towards achieving the target , work towards ensuring that

the market structures fully integrate renewable generation, so that ultimately renewable generation should at a future point be able to function in the market as a fully cost competitive technology.

• Ensure the cost effective and timely delivery of investment in the key strategic

transmission projects under Grid 25 by Eirgrid and in the distribution network by ESB Networks, so that on average at least 200MW of new renewable generation is being connected per annum to ensure we can deliver our 2020 target.

• Continue the ground breaking ‘Delivering a Secure and Sustainable Electricity System’ programme to achieve high levels of integration of wind on the energy system having regard to cost efficiency and system reliability and in line with ensuring the ability to deliver on Ireland’s EU target.

• Member States have different renewable energy potentials and operate different

national support schemes to encourage new renewable energy production. The costs of developing renewable energy projects can vary from one area to another, and other issues such as electricity grid capacity, planning and permitting timelines and market and regulatory issues can all influence the ability of a Member State to develop sufficient renewable projects in time to achieve its binding 2020 national target.

• Provided the cost benefit analysis is positive, put in place the necessary legal and

planning and infrastructure framework to support the development of onshore and offshore wind as an export opportunity without cost for the Irish consumer and to the benefit of the economy, in the context of the cooperation mechanisms under the Directive.

• Work with UK to deliver an intergovernmental agreement under the EU framework,

which will underpin, to mutual economic benefit , cross border trade in renewable energy ;

• Work with our partners in the North Seas Offshore Grid Initiative to deliver the

framework and infrastructure to support the development of the North Seas trade in offshore wind

• Commission the East West Interconnector in 2012 and continue the necessary

analysis to inform decisions on next interconnection priorities with UK and France.

• Encourage more, and cost effective, take-up of microgeneration informed by comprehensive analysis by SEAI and European and international experience and having regard to the costs and benefits.


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Strategic Goal 2: A sustainable Bioenergy sector supporting renewable heat and power generation Key Actions:

• Work on a cross-departmental and agency basis to finalise and publish the national bioenergy strategy during 2012 which will set out in detail the strategies and actions required to deliver an integrated plan-led approach to developing and utilising the resources and systematically addressing the supply and demand side issues to optimise the sector’s contribution to meeting the electricity, heat and transport targets and to job creation, economic growth and regional development

• Work with the Department of Agriculture and relevant state Agencies on policies and

measures related to bioenergy development, and the impact of proposed actions and regulation on bioenergy development.

• Liaise with Northern Ireland agencies to develop an all-island approach to developing

bioenergy resources.

• Liaise with regional and local energy authorities to ensure consistency of implementation at local level.

• Oversee implementation of REFIT 3 for biomass technologies to encourage more biomass electricity and biomass heat.

• Implement the sustainability criteria required to underpin the national Biofuels

Obligation and consult with all stakeholders this year on the optimum timing and quantum for increasing the biofuels obligation


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Strategic Goal 3: Green growth through research and development of renewable technologies including the preparation for market of ocean technologies. Key Actions:

• Publish the final Offshore Renewable Energy Development Plan during 2012.

• Department of Environment, Community and Local Government to introduce planned foreshore legislation to provide for new offshore licensing and permitting regime in 2012

• Build on the work of the ISLES study and the European Ocean technology plan and

the developing EU Energy Infrastructure Package to address infrastructural and research imperatives in a European framework

• Continue the Ocean Energy Programme in conjunction with SEAI, IDA, Marine

Institute, SFI and EI including support for the Prototype Fund, the Galway Bay/SmartBay incubator and the Marine Energy Research Centre

• Review and decide on how best to support development of the proposed grid

connected wave testing site off Annagh Point in Co Mayo including the potential for EU funding support


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Strategic Goal 4: A more sustainable Transport Sector Key Actions:

• Progressively increase the percentage level of biofuels in the transport fuel mix in line with the general biofuel limits outlined in the fuel quality directive and the EN standards for vehicle fuels, and EU market developments generally and in consultation with all stakeholders ;

• Continue current incentives for electric vehicles in 2012 and review thereafter; • Ensure the continued national roll out by ESB of Electric Vehicle recharging

Infrastructure in this pilot R and D phase as well as ensuring an appropriate regulatory and cost recovery framework is put in place for the long term

• Pursue in Europe the introduction of the necessary EU wide regulation and standards

to underpin the roll out of vehicle recharging infrastructure throughout the EU


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Strategic Goal 5: Energy networks system Key Actions:

• Maintain on an ongoing basis the cost effective delivery by Eirgrid and ESB Networks of their investment programmes in transmission and distribution networks

• Continue to make Ireland a world leader in intermittent renewable energy

integration and smart grid technology through the work of EirGrid and ongoing support, through SFI and PRTLI, for the partnership work of industry, UCD and others in the research community.

• The DS3 programme being undertaken by EirGrid is designed to manage the

achievement of our renewable electricity target from a grid perspective over the coming years. EirGrid and SONI have established a programme of work entitled “Delivering a Secure Sustainable Electricity System (DS3)”. This work programme includes enhancing generation portfolio performance, developing new operational policies and system tools to efficiently use the generation portfolio to the best of its capabilities, and regularly reviewing the needs of the system as the portfolio capability evolves. The requirement to integrate high levels of renewable energy onto the grid is a major objective for many countries and requires advanced smart grid technologies. Ireland has all the ingredients to realise first mover advantage in the development of exportable technologies related to smarter transmission and distribution of electricity, leading to employment opportunities in this area.

• Ensure that Ireland develops competitive advantage in Europe as a world centre for

energy and ICT research and innovation through alliances between research institutions, multinational companies, SMEs and start –up companies.

Note: For the full text of the Strategy please refer to www.dcenr.gov.ie.

http://www.dcenr.gov.ie/�


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Appendix 2 List of Persons who made submissions


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Pre-Draft Submissions on South Tipperary Renewable Energy Strategy

Ref No

Name Name of Organisation if relevant

1 Director of Services, Planning & Development/Community & Enterprise

North Tipperary County Council

2 Bernadette Guest Heritage Office

Waterford County Council

3 Olivia Morgan National Roads Authority NRA 4 Cian O’Mahony

Scientific Officer Environmental Protection Agency EPA

5 Joan Stone Department of Agriculture, Food and the Marine 6 Muiris O’Conchuir Department of Arts Heritage and the Gealtacht DAHG 7 Gael Gibson Eirgrid,

8 John McCann Sustainable Energy Authority of Ireland SEAI 9 Edward Sutton, PHES Ltd Cunnane Statton

Reynolds, Land Planning & Design

10 Sean Darcy Irish Wind Energy Association 11 Richard Auler Strategic Policy Committee for Planning and Economic

Development 12 Paul Overy Overy & Associates 13 Coolmore & Ballydoyle Coolmore & Ballydoyle 14 Dualla Moyglass Ballinure

Group Community Group

15 Noel Gavigan Irish Bioenergy Association 16 Barry Nelson

Development Executive Mainstream Renewable Power

17 George Mason, Chairman, South Tipperary IFA

Irish Farmers Association

18 Cllr. Louise McLoughlin South Tipperary County Council 19 Mairead Sheehan Private 20 Richard Walsh Private 21

Gemma & Peter Carvosso Private

22 Myra O’Regan Private 23 Genevieve & William Cody Private 24 Kay & Leo Cody Private 25 Aidan & Anne Marie

O’Brien Private


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Submissions received after publication of the Draft South Tipperary Renewable Energy Strategy Ref: No:

Name: Name of Organisation if relevant:

1 Joan Stone/Micheal Mackey

Department of Agriculture, Food and the Marine

2 James Carville, Cahirman Meihteal na Gaoithe 3 Thomas Cooke Cnoc windfarms 4 Thomas Cooke Biogas Environmental Tipperary East Ltd 5 Tomas Bradley An Taisce 6 Tadgh O’Mahony

Scientific Officer Environmental Protection Agency EPA

7 John Crean Cunnane Statton Reynolds, Land Planning & Design

8 Brian Dawson Irish Wind Energy Association 9 Sheevaun Thompson South East Regional Authority 10 Mary Brady DCENR 11 Frank O’Donoughe Inland Fisheries Ireland 12 Helen Mcgrath Private 13 Micheal McCormack National Roads Authority NRA 14 Stephen Walsh Irish Planning Institute


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Appendix 3 Map of Wind Energy Production Areas from County

Wind Energy Strategy

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Appendix 4: Environmental Report and Appropriate Assessment


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Table of Contents - Environmental Report 1.0 Non-Technical Summary.................................................................................................... 80

2.0 SEA Methodology ................................................................................................................... 82

3.0 Summary of the Key Objectives of the Plan .............................................................. 83

4.0 Relationship of the plan with other relevant plans and programmes ......... 84

5.0 Summary of the Baseline Environment ...................................................................... 87

5.1 Biodiversity, Flora & Fauna ........................................................................ 87

5.2 Geology & Soils ......................................................................................... 90

5.3 Soils........................................................................................................... 91

5.4 Topography ............................................................................................... 93

5.5 Landscape & Visual Amenity...................................................................... 96

5.6 Material Assets........................................................................................ 102

5.7 Cultural Heritage ..................................................................................... 104

5.8 Population & Human Health .................................................................... 105

5.9 Air/Climate Factors ................................................................................. 105

5.10 Flood Risk Assessment ......................................................................... 106

6.0 SEA Objectives and Indicators.......................................................................................109

6.1 Environmental Protection Objectives (EPOs) ........................................... 109

6.2 Development Objectives ......................................................................... 110

6.3 Consultation with Statutory Environmental Authorities. ......................... 111

Section 6.4 - Potential for Impact on the Environment Protection Objectives. ... 112

7.0 Assessment of Alternatives, and selection if preferred Alternative ............117

8.0 Mitigation Measures ...........................................................................................................117

9.0 Monitoring Proposals ........................................................................................................120

Appendix 1 : Slievenamon Bog ...................................................................................................122


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Table of Contents - Appropriate Assessment 1.0 Methodology ..........................................................................................................................126

2.0 Relationship of AA with Strategic Environmental Assessment.....................127

3.0 Screening and Scoping Processes ................................................................................127

3.1 Screening ................................................................................................ 127

3.2 Scoping ................................................................................................... 128

4.0 Consultation with the National parks and Wildlife Service (NPWS) ..........129

5.0 Baseline Environment .......................................................................................................129

5.2 Assessment of Natura 2000 sites. ............................................................ 134

5.3 Describe the likely significant impacts on the Natura 2000 site network . 135

5.4 Mitigation Measures ............................................................................... 137

6.0 AA Conclusion Statement ................................................................................................138

APPENDIX .............................................................................................................................................139


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Environmental Report 1.0 Non-Technical Summary South Tipperary County Council in conjunction with the Tipperary Energy Agency (TEA) has prepared a Renewable Energy Strategy (RES) for South Tipperary and this was endorsed by the elected representatives on 4th March 2014. The RES for South Tipperary will support the sustainable management and development of renewable energy in the county and also will act to promote the sustainable production of bio-energy as an alternative to the use of fossil fuels. The RES will be in place from 2014 to 2020, it may be reviewed at any time. The RES will be a guidance document that will support and inform the planning process. It will in due course inform statutory planning policy during the review of the County Development Plan. Whilst the RES is not a statutory planning tool it comes under the definition of: ‘A plan or programme prepared for agriculture, forestry, fisheries, energy, industry, transport, waste management, water management, telecommunications, tourism and town and country planning or landuse, and which set the framework for future development consent of projects listed in Annexes 1 and 11 to the Environmental Impacts Assessment Directive’. This the Environmental Report prepared as part of the Strategic Environmental Assessment (SEA) of the RES. SEA is the formal, systematic evaluation of the likely significant environmental effects of implementing a plan/programme before a decision is made to adopt the plan/programme; the procedures for which are set out in the Planning and Development (Strategic Environmental Assessment) Regulations 2004. Having regard to the potential for the RES to influence and guide planning policy with respect significant development related to the production of renewable energy and its application at a county level, and the resulting potential for both positive and negative impacts on the environment, it was determined that the Planning Authority should carry out SEA during the preparation of the RES.


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This Environmental Report has been prepared having consideration to the guidance outlined in the Section 28 Guidelines for regional authorities and planning authorities, on the ‘Assessment of the Effects of Certain Plans and Programmes on the Environment’, November 2004. This Environmental Report has been prepared in tandem with the preparation of the RES. A detailed assessment of how the implementation of the RES could impact on the environment was carried out in consultation with the statutory environmental authorities and where appropriate alternative solutions to the achievement of the objectives of the plan were identified. The SEA process facilitated the development of mitigation measures that will ensure that the implementation of the RES will not have an adverse impact on the environment.


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2.0 SEA Methodology The Section 28 Guidelines for Regional Authorities and Planning Authorities, on the ‘Assessment of the Effects of Certain Plans and Programmes on the Environment’ set out a methodology for the preparation of SEA. A pre-Draft SEA Scoping report was prepared in respect of the RES and consultation was carried out with stakeholders and the Environmental Authorities. Consultation was also carried out with stakeholders and the environmental authorities after publication of the Draft RES. Comments received have been considered as part of the preparation of the RES and this Environmental Report. The SEA Guidelines set out a checklist of information to be included in the environmental report, this is set out below. The application of this checklist has been a useful tool in the preparation of the environmental report.

A Outline of the contents and main objectives of the plan, and of its relationship with other relevant plans and programmes

B Description of relevant aspects of the current state of the environment and the evolution of that environment without implementation of the plan

C Description of the environmental characteristics of areas likely to be significantly affected

D Identification of any existing environmental problems which are relevant to the plan, particularly those relating to European protected sites

E List environmental protection objectives, established at international, EU or national level, which are relevant to the plan and describe how those objectives and any environmental considerations have been taken into account when preparing the plan

F Describe the likely significant effects (1) on the environment (biodiversity, human health, fauna, etc.)

G Describe any measures envisaged to prevent, reduce and as fully as possible offset any significant adverse environmental effects of implementing the plan

H Give an outline of the reasons for selecting the alternatives considered, and a description of how the assessment was undertaken (including any difficulties)

I A description of proposed monitoring measures

J A non-technical summary of the above information


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3.0 Summary of the Key Objectives of the Plan South Tipperary County Council wishes to actively facilitate and drive the development of renewable energy within its functional area through the guidance of Ireland’s national energy authority - the Sustainable Energy Authority of Ireland (SEAI). The RES has been prepared in conjunction with the input and participation of the SEAI, the Tipperary Energy Agency and the key stakeholders involved in the renewable energy sector. It has also been prepared having consideration to comments and input received from the general public and anyone with an interest in the long-term sustainable development of the county. The format and content of the RES has been derived from the SEAI’s ‘Methodology for Local Authority Renewable Energy Strategies’, March 2013. The RES will be a guidance document that will support and inform the planning process, it is for the period 2014 – 2020, and maybe reviewed at any time. It will specifically set out to:

• Seek input from the key stakeholders in the area of renewable energy. • Identify the energy needs and demands of the county to 2020 and beyond. • Identify the renewable energy resources of the county and assess the

potential for production of renewable energy. • Identify the facilitators for the development of renewable energy and

constraining factors for renewable energy production. • Set out the vision for renewable energy production in South Tipperary, this

will become planning policy when incorporated into the statutory County Development Plan.

The RES for South Tipperary will support the sustainable management and development of renewable energy in the county and also will act to promote the sustainable production of bio-energy in South Tipperary as an alternative to the use of fossil fuels. For further details on the key objectives of the RES, please refer to Chapter 1, Volume 1 of the RES.


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4.0 Relationship of the plan with other relevant plans and programmes Ireland’s planning system is based on a hierarchy of plans. The plans lower down in the hierarchy must reflect the policy approach of the plans above it in the hierarchy. The RES will be a technical support document and will thus sit at the bottom of a hierarchy of plans and strategies at the National, Regional and Local levels, and will act to inform planning policy through the County Development Plan. The International Kyoto Protocol established legally binding commitments for the reduction of Greenhouse Gasses (GHGs) produced by industrialised nations. Ireland ratified the Kyoto Protocol on the 31 May 2002, along with the EU and all other member states. As a result it is legally bound to limit the increase in its GHG emissions. Following on from the agreement of the Kyoto Protocol the EU Renewable Energy Directive required that member states describe the actions and targets for an energy policy framework, these were set out in the Government’s White Paper on Energy Policy. The White Paper set out the intention to prepare a National Renewable Energy Action Plan by June 2010. The Irish National Renewable Energy Action Plan (NREAP) sets out that by 2020, 16% of all energy demanded will be sourced from renewable resources. This is a legally binding target. In 2012, 9% of all energy came from renewable resources; this must increase to 16% over next 7 years. There are a number of other national level strategies that are relevant to the preparation of this RES, the more significant of these include the National Climate Change Strategy 2007-2012, National Energy Efficiency Action Plan 2009-2020, and the Bio-Energy Action Plan for Ireland 2007-2020. The provisions of European and National legislation with respect climate change and renewable energy are incorporated into Irish Planning law; the Planning and Development Amendment Act 2010 introduced legislation with respect the need to reduce energy demand, reduce GHG emissions and to consider the effects of climate change in new development, see below: 10 (2)(n) the promotion of sustainable settlement and transportation strategies in urban and rural areas including the promotion of measures to— reduce energy demand in response to the likelihood of increases in energy

and other costs due to long-term decline in non-renewable resources, reduce anthropogenic greenhouse gas emissions, and address the necessity of adaptation to climate change; in particular, having

regard to location, layout and design of new development; Meaningful facilitation of the renewable energy sector must be achieved and built into the planning framework for the county. It is necessary to immediately consider


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how best to achieve this objective. The review of the County Development Plan (and the ultimate development of a single Development Plan for the entire county) offers an opportunity to put in place a statutory blueprint for the development of renewable resources in Tipperary. Chapter 2, Volume 1 of the RES addresses in detail the guidelines and legislative framework that support the development of the RES. These are illustrated in figure 1 below:


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Figure 1: Hierarchy of Plans and Strategies to be considered in the preparation of

the RES

EU Directives and Protocals

• Kyoto Protocal •Renewable Energy Directive 2009/28/EU - Promotiopm of the use of energy from renewable

Sources. • EU Energy Efficiency Plan 2011-2020 • SEA & AA Requirements

National Legislation & Guidelines

•Government White Paper on Energy policy - Delivering a sustainable energy future for Ireland -

The Energy Policy Framework 2007-2020. • The National Renewable Energy Action Plan (NREAP)2010 •National Climate Change Strategy (2007-2012) •National Energy Efficiency Action Plan 2009-2020 • Planning & Development Acts 2000 - 2012 & Planning & Development Regulations 2001 - 2012 •Our Sustainable Future – A Framework for sustainable development in Ireland (DECLG 2012)

Regional Guidelines

•Regional Planning Guidelines for the South East Region 2010 - 2022 & associated Implementation Guidelines

•Regional Bio-Energy Implementation Plan for the South East Region 2008 - 2013

Development Plans

•County Development Plan 2009 - 2015 - inculding existing Wind Energy Policy 2006 •Clonmel and Environs Development Plan 2008 and Draft Clonmel and Environs Development

Plan 13 • Tipperary Town & Environs Development Plan 2013 •Carrick on Suir Town Development Plan 2008 and Draft Carrick-on-Suir Town Plan 2013 •Cashel & Environs Development Plan 2009 - 2015

Local Plans and Strategies

•Local Area Plans •Master Plans •Non-Statutory Strategies and technical support documents •Landscape Character Assessment for the Uplands and Draft Lowland Landscape

Character Assessment


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5.0 Summary of the Baseline Environment 5.1 Biodiversity, Flora & Fauna Special Areas of Conservation (SACs) SACs are prime wildlife conservation areas in the country, considered to be important on a European as well as Irish level. The legal basis on which SACs are selected and designated is the EU Habitats Directive (92/43/EEC), transposed into Irish law in the European Union (Natural Habitats) Regulations, 1997. The Directive lists (Annex I) certain habitats that must be protected within SACs. Irish habitats include raised bogs, blanket bogs, turloughs, sand dunes, machair (flat sandy plains on the north and west coasts), heaths, lakes, rivers, woodlands, estuaries and sea inlets. There is also a list (Annex II) of species, which must be afforded protection, and for Ireland this includes the Bottle-Nosed Dolphin, Otter, Freshwater Pearl Mussel and Killarney Fern. The RES is subject to Appropriate Assessment in accordance with the Habitats Directive to address the protection of Natura 2000 sites; this is set out in Volume 2 of the RES. The South Tipperary Natura sites are identified below:

Figure 2: Location of Natura 2000 Sites

The River Suir SAC is a major influencing factor on the environmental character of the county. The River Suir SAC extends along the river Suir in a north to south direction through the centre of the county and then turns north and east where the


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Suir flows from Clonmel, to Carrick-on-Suir and onwards to Waterford. It major tributaries are the Lingaun (east), Anner and Moyle (north east), Tar (south), Aherlow (west) and Multeen (north), these extend across the entire county. Water quality on the Suir and its tributaries are a major indicator of environmental quality in South Tipperary. The Council is concerned with the protection of the aquatic environment in general and will seek to ensure that any proposed projects will not conflict with the requirements of the Water Framework Directive and the requirement to maintain existing good or high ecological status waters and to improve other waters to at least good status. The status of water bodies that are designated as salmonid waters and water bodies that are an ecosystem for the freshwater pearl mussel are of particular importance in South Tipperary. The most recent complete report on water quality was published by the EPA in 2011 and is entitled ‘Report on River Water Quality in South Tipperary 20111

’ this sets out water monitoring results for 6 parameters including– ammonium, BOD, dissolved oxygen, o-phosphate, pH, o-phosphate and total oxidised nitrogen.

It is illustrated that in South Tipperary there were 17 sites with a Q value of less than good status (3-4 or less). There are up to three suspected causes of pollution listed for each site. Roughly 50% are polluted due to point sources and 50% due to diffuse sources. The EPA report also addresses physio-chemical water quality in the county and areas where water quality have changed and potential sources for change. Based on this data (water quality and assimilative capacity) it is possible to determine where surface water is most vulnerable to deterioration as a result of change in its catchment. It is also possible to determine where water bodies are most robust in terms of their capacity to accommodate extraction or discharge as a result of new development. Please refer to the Appropriate Assessment accompanying this environmental report for further detail on water quality. Other Protected Sites There are a significant number of sites located within the county designated proposed Natural Heritage Area (pNHA) with only one site actually fully designated as a NHA (protected in accordance with the Wildlife Act 2000), this is the Slievenamon Bog NHA. However, all NHAs both existing and proposed are worthy of protection. NHAs are areas considered important for the habitats present or which holds species of plants and animals whose habitat needs protection. In South Tipperary these comprise a wide variety of habitats with a broad geographical distribution across the county, including woods, ponds, marshes bogs etc. The county NHA and proposed NHAs are listed below and they are mapped in Figure 3:

1 www.epa.ie

http://www.epa.ie/�


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Natural Heritage Sites

NHA Slievenamon Bog NHA 002388

pNHA Kilcooly Abbey Lake 000958 pNHA Laffansbridge 000965 pNHA Kilbeg Marsh 001848 pNHA Dundrum 002096 pNHA Philipston Marsh 001847 pNHA Ardmayle Pond 000945 pNHA Dundrum Sanctuary 000950 pNHA Annacarty Wetlands 000639 pNHA Ballyneill Marsh 001846 pNHA Knockavilla National School 000649 pNHA Ballydonagh Marsh 001844 pNHA Doonoor Marsh 001845 pNHA Greenane Marsh 001984 pNHA Knockroe Fox Covert 000964 pNHA Power'S Wood 000969 pNHA Lizzy Smyth'S Bog 001980 pNHA Moneypark, Fethard 000966 pNHA Rockwell College Lake 000970 pNHA Quarryford Bridge 001526 pNHA Bansha Wood 002043 pNHA Grove Wood 000954 pNHA Galtee Mountains 000646 pNHA Templetney Quarry 001982 pNHA Scaragh Wood 000971 pNHA Cahir Park Woodland 000947 pNHA Marlfield Lake 001981 pNHA River Suir Below Carrick 000655 pNHA Shanbally Wood 000972 pNHA Mitchelstown Caves 000651 pNHA Glenboy Wood 000952 pNHA Aughnaglanny Valley 000948 pNHA Killough Hill 000959 pNHA Knockanavar Wood 000961 pNHA Inchinsquillib & Dowlings Woods 000956

Slievenamon Bog NHA Slievenamon Bog NHA is a site of considerable conservation significance. It contains a good example of upland blanket bog. The site is reasonably diverse in terms of species and communities due to local variation. Blanket bog habitat is a globally scarce resource. The current area of intact upland blanket bog in Ireland represents only a fraction of the original resource, due to the combined impacts of afforestation


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and overgrazing, and intact examples are therefore extremely valuable for nature conservation. The long-term survival of the NHA requires sensitive management. The Slievenamon Bog NHA is protected by SI 499 of 2005; this instrument prohibits works in the NHA as identified in the attached Schedule 2. The full SI 499 of 205 can be downloaded from www.npws.ie Please refer to Appendix 1 for further details on Slievenamon Bog NHA and SI 499 of 2005

Figure 3: Natural Heritage Areas

5.2 Geology & Soils Geology There are three ages of rock formation represented widely in the region. Youngest of all are the Carboniferous rocks (limestones) that are most widespread in Ireland, constituting most of the island’s low-lying midlands. The limestones are in-turn stratified into Westphalian and Namurian (Upper Carboniferous - the youngest rocks, underlying the Slieveardagh), and Dinantian (Lower Carboniferous - comprising the remainder of the County’s plains and valleys). Beneath and occasionally protruding through the limestones are the Old Red Sandstones of the Devonian Age. These mostly hard resistant quartzites, sandstones and conglomerates. They now form the County’s uplands, i.e. the Knockmealdowns, Galtees, Slievenamon and the Hollyford Hills.

http://www.npws.ie/�


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At the crests of the Galtees, Slievenamon and the Hollyford Hills, Silurian Age rocks, the oldest encountered in the County, have been exposed by erosion of the Old Red Sandstones. These highly compacted slates, shales and greywackes formed between 400 and 435 million years ago.

Figure 4: Geology of South Tipperary The major geological divisions within the County, as indicated in Figure 4 below, are those between the Lower Carboniferous rocks and the Old Red Sandstones. The more substantial areas of Upper Carboniferous and Silurian rocks have also been delineated.

5.3 Soils The soils of South Tipperary are a complex product of the bedrock geology and the various geomorphological processes that have subsequently acted on the region, such as the spread and retreat of the ice sheet and glaciers. This is reflected in the subsoil geology, which is dominated by limestone till (glacial deposits) on the plains and shallow rock in the uplands. The principal soils of the Knockmealdowns, Galtees, Slievenamon and the Hollyford Hills are Peaty Podzols, with low nutrient status and peaty surface. Outcropping rock

Devonian rocks (Old Red Sandstone)

Silurian rocks

Other

MAJOR ROCK GROUP DIVISIONS

Westphalian (upper carboniferous)

Namurian (upper carboniferous)

Dinantian (lower carboniferous)

10

Carboniferous rocks

0 5

kilometres


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is common and the soils are poorly drained. These characteristics limit the land capability to marginal grazing and forestry. On the lower slopes of the uplands, Gleys are common. Being poorly drained, intermittently waterlogged, sticky and hard to work, the land use capability here is similarly limited, although the material is deeper. In the Slieveardagh hills and the western and eastern extents of the southern lowland plains (between the major uplands), there is widespread coverage of Acid Brown Earths. These soils are similar in nature to the Brown and Grey Podzols that cover the northern and central plains, and which give the Suir Valley region its name, the Golden Vale. They are deep, free draining and medium textured with a good moisture holding capacity, making the majority of the county’s plains of wide land capability, suitable for high quality grassland and tillage. The soils of the Golden Vale are renowned for their quality and ability to produce high quality bloodstock, crops and livestock. The agricultural and equine resources of the county are to a large extend dependant on the quality of the soils of the central plain. To the north west of the Slievardagh, along the county boundary with North Tipperary, there are extensive patches of Basin Peat, naturally very limited in terms of land capability. Whilst this peatland is limited in its productive capacity, it is a unique lowland resource in the county and offers a diverse peatland habitat that should be recognised. The major soils divisions within the County are therefore those between the high quality soils of the lowland plains (the Golden Vale) and the shallow, nutrient poor and poorly drained soils of the uplands and the peatland area in the north east (See Figure 5). In terms of baseline environment, the quality soils of the lowlands are highly productive and intensively managed as an agricultural resource. The ability of this land to maintain it’s productively is vital to the economy of the county. The soils of the uplands and the peat lands are less intensively managed and have a lower economic productively, however, as a result of this have a greater diversity and this also enhances the environmental and visual quality of the county.


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Figure 5: Soils of South Tipperary

5.4 Topography The Upland Areas The Knockmealdown Mountains are situated in the south west of the County. The northern slopes of the range rise steeply to a linear series of peaks between 500m and 800m in elevation. The uniformly steep north-facing slopes are deeply incised by glacial and river valleys flowing directly northwards onto a narrow plain shared by the Duag and Tar Rivers. The range decreases in elevation and gradient towards the east and west where the valleys and peaks are less pronounced. The elevated Araglin River valley along the county boundary south of and parallel to the range is a significant feature. The Commeragh Mountains, although not within the county boundary, are an important topographical feature of the county and form an important visual backdrop to the county town of Clonmel. Together with the Knockmealdowns to the

Gleys

Basin peatBlanket peat

Acid brown earths

Redzinas with outcropping rock

MAJOR SOILS DIVISIONS

Lithosols & outcropping rock

Brown and grey podzolics

Peaty podzols

105

kilometres

0


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west, they form an impenetrable barrier to the Suir River flowing from the north. The river skirts their northern slopes on its eastward path towards the Waterford coast. The Galtee Mountains, parallel to, and some 10km north of the Knockmealdown’s, are Ireland’s highest inland range, rising to an elevation of between 500m (its eastern and western-most peaks) and 920m (Galtymore). The southern slopes of the linear, east - west range are less steep and more convoluted than the northern slopes, which are characterised by corries at the upper reaches of broad glacial valleys. The Galtee Mountains are a SAC (and a pNHA) in view of the important habitats they host, set out below:

• European dry heaths • Alpine and Boreal heaths • Species‐rich Nardus grasslands, on siliceous substrates in mountain areas

(and submountain areas, in Continental Europe) • Blanket bogs (* if active only) • Calcareous rocky slopes with chasmophytic vegetation • Siliceous rocky slopes with chasmophytic vegetation

The protection of the special characteristics of the Galtee Mountains will be a key consideration in the future development of the county. North of and parallel to the Galtee’s is Slievenamuck, a narrow, steep-sided sandstone ridge rising to an elevation of 370m. Separating the Galtees and Slievenamuck, defined by their steep slopes, is the Glen of Aherlow, a strip of relatively flat limestone plain tapering from 5km in width at its eastern extent to roughly 2km at its narrowest along the County’s western boundary. The Glen of Aherlow is known for its natural visual beauty and is an important tourism asset in the county. Slievenamon, the county’s most distinctive topographical feature, is also an east – west orientated upland. The mountain rises steeply from the surrounding plains to a peak of 720m at its western extent. Drainage channels radiate outwards in all directions from Slievenamon, those flowing north, west and southwards feeding the Suir River’s tributaries on the plains below. Those flowing eastwards emerge onto an elevated valley of glacial origin, occupied by the Lingaun River. The valley is rimmed along its northern and southern edges by hills, the outer slopes of which drop steeply down to the surrounding plains. Slievenamon is a NHA (Slievenamon Bog), this pretty mountain is also integral to the folklore of Tipperary and its visual, natural and mythological heritage is very significant. The Hollyford Hills occupy the north western portion of the County. The Hills are the southern extent of the Slievefelim Mountain Range, which extends north and westwards into the neighbouring counties. The stratum of Old Red Sandstone is completely eroded here, exposing a core of relatively soluble Silurian siltstone, greywacke and grit. The Hills’ orientation is in keeping with the NNE /SSW grain


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characteristic of Ireland, and less linear in nature. Consequently, the Hills are a more random arrangement of rounded hilltops between 350 and 450m in elevation, drained by a number of streams and rivers flowing west, south and eastwards in steeply incised valleys onto the surrounding plains. The Hollyford Hills are a SPA where they adjoin the north Tipperary County Boundary, and the protection of the special characteristics of the SPA is a key consideration in the future development of the county. The Slieveardagh hills in the north east of the county are composed of soluble Upper Carboniferous (limestone) rocks. Their grain is also NNE / SSW. The Slieveardagh arise as low hills on the central plain of the county, increasing in elevation towards the north east, where Knocknamuck, at an elevation of 340m, is the highest point. The Slieveardagh’s rounded hilltops are separated V-shaped valleys of even gradient, typical of a ‘young’ limestone landscape. The northern / north western edge of the Slieveardagh is a steep scarp slope that rises roughly 100 to 150m above the flat bog lowlands to the north.

Figure 6: South Tipperary Elevations

Ascending Elevation


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The Lowlands Topographical variations in the lowlands of the county are gradual and subtle. It is possible to consider river catchments and the interrelationship of topography and drainage to loosely sub-divide the lowlands along the boundaries of the main river catchments. Another key influence of the character of the lowlands is the urban structure of the county and this settlement structure and associated infrastructure also defines the county’s lowlands character. The visual relationship of the lowlands with the adjoining uplands areas is also important to the character and visual quality of the lowlands, and this is an important consideration for commercial wind energy development. In this respect the County Landscape Character Assessment has identified Visual Units2

5.5 Landscape & Visual Amenity

to assist in the determination of the key area of visual quality in the county. New development proposed in the county will be required to illustrate that it will not interfere with the special visual character of the visual units when viewed from adjoining low land areas. Please refer to Section 6.5 below for detail on landscape and visual amenity.

In 2006 Cunnane Stratton Reynolds produced a Landscape Character Assessment (LCA) of the uplands in the county; this is now being completed for the entire county by the production of a character assessment of the lowlands of the county. The LCA resulted in the designation of the following character areas: The eight upland LCAs identified in South Tipperary are as follows:

• The Knockmealdown mountain mosaic of moorland, forestry and marginal pasture. This area includes a sub-area comprised of the Araglin River Valley, which straddles the County boundary with Waterford, south of and parallel to the mountain range. The lesser peaks to west and east of the range are also considered sub-areas of the LCA.

• The Galtees mountain mosaic of moorland, forestry and marginal pasture. This area is comprises the southern face of the Galtee mountains including an extensive area of cSAC designated land, the Galtee Mountains SAC. This area of upper slopes and peaks is considered a sub-area of the LCA.

• The Slievenamuck marginal mosaic of forestry and marginal pasture. This area comprises the almost entirely forested northern face of Slievenamuck.

• The Glen of Aherlow marginal and farmland mosaic of moorland, forestry and varying pasture. This area comprises the Aherlow River valley, narrow strip of flat to undulating farmland mosaic between the northern face of the Galtees and the southern face of Slievenamuck, which are included in the area.

2 Areas defined by spatial enclosure and pattern, determined by landform and land cover – Landscape and Landscape Assessment, Department of the Environment and Local Government, June 2000.

Map 4: Flood Zones


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• The Slievenamon mountain mosaic of moorland, forestry and marginal pasture. This area includes the primary and lesser peaks of Slievenamon at the western extent of the upland, as well as the outer slopes of the hills enclosing the Lingaun river valley to the east of the peak. These outer slopes are considered sub-areas of the LCA.

• The Lingaun Valley marginal and farmland mosaic, of moorland, forestry and varying pasture. This area comprises the valley of the Lingaun River extending eastwards from the peak of Slievenamon, including the inner slopes of the hills defining the northern and southern edge of the upland.

• The Hollyford Hills mountain mosaic of moorland, forestry and marginal pasture. The Cahernahallia and Multeen River valleys, are both visual units in which a distinct sense of enclosure is perceived. These are considered sub-areas of the LCA.

• The Slieveardagh Hills farmland mosaic of varying pasture, tillage and private forestry. The Anner River ‘bowl’ which forms the source of the river in the southern hills of the upland can also be described as a visual unit, and is considered a sub-area of the LCA. The northern slopes of Slievardagh form a steep escarpment that overlooks and shelters the villages of Ballinunty, Gortnahoe, Ballysloe and Grange. In turn these villages overlook the Littleton mixed farm and peatlands to the north.

The three lowland character areas (proposed3

) have been identified as follows:

• The River Suir Central Plain (also know as the ‘Golden Vale’) – is the most extensive and coherent landscape area in the county. It forms the expansive central area of the county where it is associated with the River Suir and also extends west along the tributaries of the Multeen, Thonouge and Tar and eastwards along the Anner. The River Suir Central Plain is characterised by its rich and productive agricultural lands and rolling landscape. The River Suir Central Plan incorporates the large towns of the County and many settlements and villages. The M8 Motorway transverses the central plan in a neat east – west divide. The six main towns and urban areas form a sub-area of this LCA.

• Sub Area: Town and Urban Fringes of Clonmel, Carrick-on-Suir Town,

Tipperary Town, Cashel, Cahir and Fethard. The main urban areas of the county form a landscape character area in their own right and are distinctive from their surrounding agricultural hinterlands. The town and urban fringes are characterised by mixed suburban and transitional lands in the town environs and denser more built up central areas. Each of the urban areas were built on rivers with the exception of Cashel

3 The Lowland LCA is at draft Stage and may be subject to change.


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• West Tipperary Farmland Mosaic - The landscape to the west of Tipperary Town and including the settlements of Kilross, Emly and Cullen is distinctive in character from the River Suir Central Plan. This area is more isolated in its character and its farmland is slightly more marginal and undulating in its topography when compared with the rich agricultural lands of the Suir Valley.

• Littleton Farmland Mosaic and Marginal Peatland – to the north of the

county along the northern slopes of the Slieveardagh Hills lies an area distinctive from the Suir Valley and the Slieveardagh Hills Farmland Mosaic. The Northern Slopes of the Slieveardagh Hills forms a steep escarpment that overlooks this area and lends it a distinctive character. The area is also characterised by its association with the raised bog peat lands of North Tipperary and the Midlands. The Littleton peat briquette factory is located in this area, however, the productive peat lands are generally located further north.

The LCA process includes for an assessment of Landscape Capacity or the ability/capacity of the landscape to accommodate change without loss to its intrinsic values or character, alternatively can be defined as ‘sensitivity to change’. Landscape capacity is classified into 5 classes with Class 1 being unique landscape (landscape that is highly sensitive with low capacity to change) and Class 5 being landscape of low sensitivity (or landscape able to accommodate appropriate new development and change without loss to its character). The county landscape capacity classification is set out below. The lowland areas outside of the upland areas are considered to be more robust in their ability to adsorb change without loss to their values and character (compared to the uplands areas) and therefore are proposed to be designated as Class 54

4 Consultation on Landscape Character is currently ongoing and will be incorporated into this SEA process when complete.

.


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Figure 7: Upland Landscape Sensitivity Classification

Protected views as identified in the County Development Plan Protected views are identified in the County Development Plan throughout the county, these are indicated as either protected view points or protected views when considered along a particular route. The protected views are outlined in the appendices to the County Development Plan at www.southtippcoco.ie, and are illustrated in the map below. New development proposals will be required to comply with the County Development Plan with respect the protection of views and vistas in the county.

http://www.southtippcoco.ie/�


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Figure 8: Protected Views

Wind energy Development in the South Tipperary Landscape New development proposals will be required to ensure that the special landscapes and prospects of the county are not affected in a detrimental way. Commercial wind energy development is often located in upland areas and can result in change in the landscape. The South Tipperary County Council Wind Energy Policy adopted in 2006 identified areas preferred for wind energy development (Please refer to Figure 8 below for map setting out wind energy areas). It should be noted that ‘preferred areas’ or suitable areas for wind energy development were designated after Landscape Character Assessment and SEA, therefore, the existing Wind Energy Strategy 2006 for the county addresses the protection of the landscape by ensuring that commercial wind developments are located in areas that are not visually sensitive. The Wind Energy Strategy has identified a number of areas where commercial wind energy development is not permitted (Red), these areas include the Galtee Mountains, The Knockmealdown Mountains, Slievenamon, the Hollyford Hills SPA areas, and parts of the Dualla Areas and Ahenny Areas. It has also identified areas that are most viable for wind energy development based on wind speed (Green); these areas include the Hollyford Hills and the Slieveardagh, Ballingarry and Drangan areas. Public participation carried out at the time of the


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making of the wind energy strategy resulted in the removal of parts of the areas considered viable for wind energy (Dualla and Ahenny). All other areas of the county are considered open for consideration for commercial wind energy (Orange) however; they may not be commercially viable as a result of lower wind speeds. Cumulative Visual Impact of Wind energy Development As of January 2013, 84 commercial wind turbines are permitted in South Tipperary. These were permitted as part of 13 different planning applications and are clustered in three distinct areas in the county, notably, the Cappawhite and Hollyford Hills area (63 turbines), Dualla area (16 turbines) and North of the Commons (5 turbines). In view of the need to exploit the higher wind speeds of the areas designated as suitable for development of wind turbines, it is expected that new large-scale proposals for wind energy development will continue to be focused on the areas identified as suitable for development of wind turbines, However, it is recommended that the cumulative visual impact and especially the cumulative visual impact on the visual units5

of the county of both permitted and not constructed and constructed wind farms be an important consideration in any planning application for wind energy development in the future.

In order to assist the planning authority in assessing cumulative visual impact of wind energy development a GIS database of the location of all wind energy developments has been created and new wind energy developments as they may occur will be mapped. In addition to this, in applying the Wind Energy policy of the County Development Plan, the Council will actively encourage developers and investors to consider the cumulative impact of wind energy development in areas where wind developments have already been permitted. Reference in this respect may be made to the Wind Energy Guidelines 2006 and to the Scottish Natural Heritage Guidelines - Assessing the Cumulative Impact of on-Shore Wind Energy Developments 2012. Please refer to Figure 9 below for details of areas where wind turbines have been permitted and for an illustration of the wind energy policy of the county development plan.

5 Key Features of the Landscape - Refer to the Landscape Character Assessment for details of county visual units.


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Figure 9: Permitted Wind Energy Developments and Wind Energy Policy areas

5.6 Material Assets South Tipperary has a wealth of material assets including but not limited to private housing, transport and public service infrastructure, commercial and industrial enterprises, the agricultural and equine industries, amenity and recreational facilities, quarries and agricultural land (cultural assets dealt with below). The material assets of the county that may be relevant for the production of bio-energy include areas of uplands suitable for wind energy production, land banks suitable for the production of crops and forests, water bodies etc, the potential of these resources is dependent on the county’s infrastructure such as road network, water supply network, wastewater network, electricity supply network, gas network etc. it will be a function of the SEA to ensure that the sustainable development of renewable energy will not have a detrimental impact on the important material assets of the county.


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Figure 10: Land cover in South Tipperary. Renewable energy developments generally can be categorised by scale. In general, development may be proposed at either a commercial scale or a micro scale. Private or micro-level development i.e. domestic wind turbines are generally acceptable in all parts of the county subject to a case by case assessment. Medium scale developments i.e. on-farm anaerobic digester in general are suitable in most parts of the county, where they do not interfere with residential amenity and/or the integrity of the environment etc. Large scale or commercial level development proposals, i.e. commercial wind turbines, large scale anaerobic digester dependant on imported feedstuffs have a much greater capacity to impact on their receiving environment. In the case of proposals for large scale developments, the impact that they will have on the environment and material assets of the county will be closely examined by the planning authority. Any proposals for very large renewable energy developments


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that will generate significant levels of traffic or demands on infrastructure i.e. gas, water will be required to locate in areas that have the capacity (both environmental and infrastructural) to accommodate them. The key considerations will be the potential for impact on water quality (surface and ground), flooding, impact on agriculture and the equine industries, impact on transport infrastructure and road traffic safety, emissions, visual and residential amenity.

5.7 Cultural Heritage South Tipperary has a wealth of architectural and cultural heritage and this is vital to the character of the county and to its tourism industry. Protected structures are set put in the relevant Development Plans and are given statutory protection in the Planning and Development Acts 2000-2013. Sites and Monuments are protected by the National Monuments Act and identified in the relevant Development Plans. The County Heritage Plan addresses cultural and natural heritage in general and sets out actions and measures for its protection and maintenance. It is unlikely that the development of renewable energy resources would have a significant or far-ranging impact on cultural heritage. Potential visual or physical impacts would generally be localised and can be minimised by tools such as visual impact assessment, archaeological assessment etc.

Figure 11: Location of National Monuments and Protected Structures


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5.8 Population & Human Health Population South Tipperary has strong settlement structure based around its county town of Clonmel, its larger towns and its strong network of small towns and villages. There is also a well dispersed rural population, and the county is populated over much of its area with the exception of the higher upland areas and bogland areas to the extreme north of the county. The county traditionally has had a strong agricultural and equine industry with population living on the land near their place of work. The RES will aim to protect and enhance the vitally of the agricultural and equine industries of Tipperary. Human Health South Tipperary is considered to be a quality place to live and its natural and cultural amenities and facilities contribute to a high quality of life. It is envisaged that the reduction in the use of fossil fuels as proposed will contribute to a higher quality of life through the lowering of the production of GHG emissions. However, it will be a function of this SEA to ensure that the sustainable development of renewable energy will not have a negative impact on human health. Wind energy developments have resulted in concerns from members of the public in relation to potential impact on human heath as a result of noise and shadow flicker in the vicinity of wind turbines. The Department of Environment, Community and Local Government is currently carrying out a technical update of the Wind Energy Development Guidelines 2006 with respect noise (including separation distance) and shadow flicker from wind energy developments. This update is intended to ensure that the Wind Energy Guidelines are supported by a robust and up to date evidence base on these issues to support wind energy development in a manner which safeguards residential amenity consistent with EU and National Policy. For further detail on the update process refer to www.environ.ie. South Tipperary County Council will apply the recommendations of the Wind Energy Guidelines as amended with respect noise and shadow flicker.

5.9 Air/Climate Factors A suite of new EU Directives setting out a completely new approach to the monitoring, assessment and management of air quality has been adopted in recent years. The objectives include avoiding, preventing and reducing the impact of harmful air emissions on human health and the environment. Ireland does not have serious outdoor air quality problems. This is largely due to the eradication of the burning of coal in many urban areas during the 1980s and the early 1990s. The biggest threat now facing our air quality is emissions from road traffic. Air pollution can affect the health and well-being of sensitive population groups and eco-systems. The Environmental Protection Agency (EPA) has overall responsibility for the co-ordination of ambient air quality monitoring in Ireland in accordance with these EU Directives.



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The EPA and local authorities operate monitoring stations. South Tipperary is located within Air Quality Zone C and the current air quality in this zone is of good status (taken from the monitoring point at the Limerick City Council laboratories on Park Road, Reebogue, Limerick). It is likely that the implementation of the RES will have long-term benefits with respect air quality and climate change. However, any localised potential for adverse effects will be managed through the appropriate procedures and controls such as EIA, IPC Licencing etc.

Figure 12: Population, Settlement and Transport Infrastructure

5.10 Flood Risk Assessment It is a critical element of the SEA to consider the potential for flood risk as a result of development and to ensure that the potential impact of flooding on new development is a careful consideration of the planning process. It is also important to consider the impact of Climate Change on flood risk in the long-term. Flooding is a multi-functional natural process which performs important ecological roles and which always has and always will occur. Flooding is important in the context of the baseline data for the SEA of the Plan, as it is likely to act as a constraint on the development of lands. Figure 13 identifies lands within Flood Zone A and Flood Zone B (as per JBA Flood Mapping purchased by STCC in 2010) and the


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1:100 and 1:1000 Year Preliminary Flood Risk Mapping (PFRA) produced by the OPW in 2012. These are the only currently available flood risk maps for South Tipperary. The OPW in conjunction with RPS Consultants are currently preparing a South East Catchment Flood Risk Management Plan (CFRMP) and a River Suir CFRAM, these will identify areas for flood management (generally based around urban areas) and will be important management tools for flood risk areas in the future. South Tipperary is primarily located in the Suir River Catchment. The OPW have identified 23 Areas for Further Assessment (AFAs) and detailed flood Maps will be prepared for these areas in 2014. The AFAs for the Suir catchment are set out below.

Figure 13: OPW AFAs on the Suir Catchment

Any new development proposed in the county will be required to demonstrate that it will not contribute to flood risk in accordance with the Flood Risk Guidelines and having consideration to available Flood Risk Mapping, including flood risk mapping from the OPW/RPS Suir CFRAMs and SE CRFRAMs due to be published in 2016. Where appropriate the council will request the preparation of a flood risk management plan to accompany planning applications.


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Figure 14: Preliminary Flood Risk Areas


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6.0 SEA Objectives and Indicators 6.1 Environmental Protection Objectives (EPOs) The focus of the RES is on the promotion of the production and use of renewable energy in the county as an alternative to the use of fossil fuels, therefore, it ultimately will have the protection of the environment through the decrease in the use of fossil fuels at its core. SEA scoping was carried out for the RES to determine the key environmental impact areas, and how these areas may be affected (positive or negative) through the implementation of the RES. The key Environmental Protection Objectives (EPOs) of the County Development Plan are set out below:

Table 1: EPOs relevant to the implementation of the Plan

Environmental categories

Environmental Protection Objectives (EPOs)

Biodiversity, Flora & Fauna

• Conserve the diversity of habitats and protected species

Water Quality and Flooding

• Promote sustainable water use based on long-term protection of available water resources.

• Protect and enhance the status of aquatic ecosystems and, with regard to their water needs, terrestrial ecosystems and wetlands directly depending on the aquatic ecosystems.

Landscape and Visual Amenity

• Conserve and enhance valued natural and historic landscapes and features within them.

Air & Climatic Factors

• Reduce all forms of air pollution. • Minimise emissions of greenhouse gases to

contribute to a reduction and avoidance of human-induced global climate change.

• Reduce waste of energy, and maximise use of renewable energy resources.

• Assess, plan and manage adaptation to climate change impacts.

Material Assets • Maximise the use of the existing built environment.

• Avoid flood risk and / or coastal erosion in selecting sites for development.

Cultural Heritage • Promote the protection and conservation of the

cultural, including architectural and archaeological, heritage.

Population and • Minimise noise, vibration and emissions from


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human health traffic, industrial processes and extractive industry.

Soils & Geology • Maintain the quality of soils • Give preference to the use of brown field lands,

rather than developing Greenfield lands. • Minimise the consumption of non-renewable sand,

gravel and rock deposits. • Minimise the amount of waste to landfill.

6.2 Development Objectives It is likely that the implementation of the RES may lead to and facilitate the following key areas of development: Typical Development Types that may arise as a result of the implementation of the RES All forms of Micro renewable energy resource collectors – Private wind turbines, solar panels, private combined heat and power units, small scale anaerobic digestion etc. Macro Renewable forms Commercial Hydropower – Development of upland hydropower facilities to generate electricity from stored water, development of lowland water resources through impoundment or diversion. Commercial Bio-Energy – Anaerobic digestion facilities at the medium to large scale, bio fuel production facilities etc Commercial Wind Energy – Wind turbines on upland areas and individual turbines developed on sites to provide for the energy needs of enterprise and industry. Bio-Energy Cropping – Growth of crops for production of energy i.e. willow, miscanthus, sugar beet, oilseed rape etc. Commercial Geothermal Units – Large scale geothermal collectors Commercial Solar Units – large scale photovoltaic or solar collectors In the context of development that may arise as a result of the RES there is potential for interaction between the EPOs set out above and the development objectives. It is important to note that many of the inter-relationships may be positive or neutral. There may also be potential for negative interactions in the absence of appropriate


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mitigation measures and therefore it is important that all interrelationships are properly considered through the SEA process. Note: It is important to acknowledge that the development of the renewable energy sector and the increased use of bio-energy as an alternative to the use of fossil fuels will have far-reaching benefits for all of the environmental indicators.

6.3 Consultation with Statutory Environmental Authorities. In February 2013, the Planning Authority submitted a detailed RES scoping Report to the statutory Environmental Authorities in order to gain their input into the SEA Scoping Process. The Environmental Protection Agency set out their recommendations with respect preparation of the RES, the key recommendations are set out below:

• Incorporate the potential for phased renewable energy developments. • Consider other influential plans/programmes/strategies and related SEAs. • Consider adjacent local authority wind/renewable energy strategies. • Consider landscape character including the definition of landscape under the

European Landscape Convention. • Consider EU guidance in relation to ‘Wind Energy Developments and Natura

2000 sites’ – EU Commission October 2010). • The SEA and AA should assess the full range of environmental effects as set

out in the SEA Directive and Habitats Directive. In particular potential cumulative and in-combination effects associated with other relevant plans, programmes and projects should be assessed. This assessment should also account for the potential for likely significant effects associated with construction, operation, maintenance and commissioning effects of renewable energy development. The impacts associated with related infrastructure such as construction roadways, site investigations, power liens etc. should be taken into consideration.

• In the assessment of development scenarios, consideration should be given to ensuring that the proposed alternative scenarios are both realistic and reasonable.

• Refer to the Wind Energy Guidelines, noting that proposals for wind energy development may be subject to EIA and Appropriate Assessment including visual assessment.

• The potential for impact on designated national and international nature conservation sites should be considered.

• A commitment should be given that to require Appropriate Assessment Screening to be carried out for all plans, programmes and projects that may arise in the implementation of the Strategy.

• Existing Heritage/Biodiversity Action Plans should be considered and habitat mapping etc should be part of the consideration of the SEA.

The statutory consultees were also consulted at the publication of the Draft RES, in November 2013. A response was received from the following:


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• The EPA • Inland Fisheries Ireland • The Department of Agriculture, Food and the Marine

The comments made by the statutory consultees were summarised and responded to in the report on submissions prepared for the RES and the key areas of comment are outlined below:

• It should be ensured that development of renewable energy resource is sustainable and does not impact on water ecology and the objectives of the Water Framework Directive in the short or long term. Particular care is required at the construction phases of windfarms, hydropower and micro-renewables. Care is also required at the operational phases of hydropower developments

• It was recommended that the renewable energy polices of both North and

South Tipperary be carried out as soon as may be appropriate after the amalgamation.

• It shall be the policy of the Council to require Natura Impact Assessment at

planning application stage and to carry out Appropriate Assessment (AA) screening where proposed renewable energy related development has the potential for significant effects on Natura 2000 sites.

• It was recommended that cumulative impacts of wind energy development

should be assessed as part of the planning process for wind energy developments.

• Consideration should also be given to the identification of locations for large

scale bio-energy and hydropower developments in the County.

• The environmental sensitivities of the county and how they may be impacted upon as a result of the development of renewable erg should be fully assessed and incorporated into the RES.

• The assessment of alternatives should consider the impact on the environment in the event that the RES is not implemented.

All comments made by the statutory environmental authorities have been given due consideration during the preparation of the RES and this Environmental Report.

Section 6.4 - Potential for Impact on the Environment Protection Objectives. The Matrix below assesses the areas where the development objectives of the RES may interact with the SEOs set out in this environmental report. Where it is identified that there is potential for a significant adverse impact on an SEO, mitigation measures are proposed for incorporation into the RES.


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Potential effects on SEOs are categorised as follows:

√ Significant beneficial impact ? Uncertain Impact X Significant adverse impact O No relationship, or insignificant impact.

Table 2: Matrix of interaction of EPO’s with Development Objectives.

Environmental categories


Potential Impact (√, ?, X, O)

Comment


Conserve the diversity of habitats and protected species

? √ The development of renewable energy sources especially that element of the industry that relates to processing could potentially have wide- ranging and localised adverse impacts on biodiversity through the construction and operation phases of development. The types of renewable energy development that could impact on Biodiversity, Flora and Fauna are generally the larger scale or commercial systems such as biofuel/biomass processing, hydro-energy installations, bio-energy cropping, large-scale wind energy installations etc. More localised impacts could arise as a result of domestic scale installations such as small scale hydropower installations, on-farm AD plants, wood chipping facilities etc. The greatest level of impacts could typically arise at the construction phase; however, for many of the developments identified above the on-going operating of the facilities could result in environmental impacts. In addition the decommissioning phase should be considered as part of any development. Appropriate planning policy for environmental protection and mitigation measures should be incorporated into the RES in support of the County Development Plan Policy, to avoid conflict with the EPO for Biodiversity, Flora and Fauna.


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Promote sustainable water use based on long-term protection of available water resources. Protect and enhance the status of aquatic ecosystems and, with regard to their water needs, terrestrial ecosystems and wetlands directly depending on the aquatic ecosystems.

? √ The protection of water quality in South Tipperary is influenced by the extensive designation of water courses as Special Areas of Conservation associated with the River Suir catchment and the requirements of the Water Framework Directive. The types of renewable energy development that could impact on water quality (as a result of disturbance or abstraction/discharge) are generally the larger scale or commercial systems such as biofuel/biomass processing, hydro-energy installations, bio-energy cropping, large-scale wind energy installations etc. More localised impacts could arise as a result of domestic scale installations such as small scale hydropower installations, on-farm AD plants, wood chipping facilities etc. The greatest level of impacts could typically arise at the construction phase; however, for many of the developments identified above the on-going operating of the facilities could result in environmental impacts. In addition the decommissioning phase should be considered as part of any development. Appropriate planning policy for environmental protection and mitigation measures should be incorporated into the RES in support of the County Development Plan Policy, to avoid conflict with the EPO for Water quality and flooding. The avoidance of flood risk or the exacerbation of existing flood risk should also be considered in the county and consideration of flood risk areas and flood risk management plans (after publication of the Suir CFRAMs) will be required as part of any planning proposal.


Conserve and enhance valued natural and historic landscapes and features within them.

? Certain aspects of the renewable energy sector can alter views and prospects, i.e. wind turbines, intensive forestry, processing facilities, solar harvesting. There is also potential for localised visual impacts as a result of the development of micro-renewables.


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* ‘Preferred areas’ or suitable areas for wind energy development have already been set out in the County Development Plan and were subject to Landscape Character Assessment prior to their identification, therefore, the existing Wind Energy Strategy for the County addresses the protection of the landscape. In the event that it is proposed to amend the Wind Energy Strategy, the implications for impact on the landscape will be revisited.


Reduce all forms of air pollution. Minimise emissions of greenhouse gases to contribute to a reduction and avoidance of human-induced global climate change. Reduce waste of energy, and maximise use of renewable energy resources. Assess, plan and manage adaptation to climate change impacts.

√ It is envisaged that the increased focus on the production of energy from clean and renewable resources such as wind, water and sunlight will over the long turn improve air quality and have a positive impact on climate change due to the reduction in reliance on the burning of fossil fuels. Adverse impact on air quality is likely to be most associated with biomass processing and burning. Domestic burning of wood fuel is becoming more efficient and produces lower rates of emissions due to better quality stoves and technology. Emissions may occur at the large scale in the event of the location of a large scale bio fuel processing facility in the county i.e. wood pellet manufacturing or bio-fuel processing. The greatest level of impacts could typically arise at the construction phase; however, for many of the developments identified above the on-going operating of the facilities could result in environmental impacts. In addition the decommissioning phase should be considered as part of any development. Appropriate planning policy for environmental protection and mitigation measures should be incorporated into the RES in support of the County Development Plan Policy, to avoid conflict with the EPO for Air Quality and Climate Change.

Material Assets

Maximise the use of the existing built environment.

?, √ The potential for impacts on certain material assets could arise as a result of significant changes in agricultural practices i.e. through bio-energy cropping, of the erection of large scale processing. Localised


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Avoid flood risk and / or coastal erosion in selecting sites for development.

impacts on the assets of the county in general i.e. infrastructure, could arise as a result of individual proposals for development.

Cultural Heritage

Promote the protection and conservation of the cultural, including architectural and archaeological, heritage.

O It is considered that the implementation of the Plan will not have significant negative impacts on the cultural heritage of the plan area. Local impacts that may arise may be mitigated through the planning process.

Population and human health

Minimise noise, vibration and emissions from traffic, industrial processes and extractive industry.

O It is considered that the implementation of the Plan will not have significant negative impacts on the human health of the population of the plan area. Local impacts that may arise may be mitigated through the planning process.

Soils & Geology

Maintain the quality of soils Give preference to the use of brown field lands, rather than developing Greenfield lands. Minimise the consumption of non-renewable sand, gravel and rock

O It is considered that the implementation of the Plan will not have significant negative impacts on the soils and geology of the plan area. Impacts are generally localised and associated with ground disturbance as result of development in upland or peatland areas, these include landslides or bog bursts, such impacts may be mitigated through the planning process.


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deposits. Minimise the amount of waste to landfill.

7.0 Assessment of Alternatives, and selection if preferred Alternative There are two potential alternatives for development of Renewable Energy that may occur. Baseline Scenario – This refers to a scenario of ‘business as usual’ or alternatively could be described as the situation that would arise in the absence of a RES and would occur where all policy measures legislated for are maintained, however, no proactive approach to renewable energy development and support is considered. This would represent a hypothetical future scenario in which no further policy actions or collaborative measures including all stakeholders are taken. Such an approach would result in a slow increase in the production of renewable energy however, would fail to meet 2020 renewable energy production targets for the reduction in reliance on fossil fuels and the consequent increase in the production of and use of renewable energy. NREAP Scenario - This scenario is to occur in line with the implementation of the baseline measures described above and in addition to these, the implementation of the NREAP targets. The NREAP details a pathway for Ireland to meet the binding commitments of 16% Renewable Energy Share of national energy consumption by 2020. In addition, the implementation of the National Energy Efficiency Action Plan (NEEAP) targets in conjunction with the NREAP targets will achieve 20% energy efficiency savings, thus contributing to the achievement of the nationally binding 2020 targets. It is the vision of the Council to implement the NREAP Scenario through the measures outlined in the RES.

8.0 Incorporation of mitigation measures and assessment results into the Plan This SEA process is concerned with ensuring that the implementation of the plan will have the minimum impact on the environment having consideration to alternatives. It has been determined that the implementation of the plan will have in certain cases an impact on the environment (Environmental Protection Objectives),


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therefore, it is necessary to ensure that the RES incorporates measures to mitigate and minimise any adverse impact on the environment as a result of the implementation of the Plan. The recommended mitigation measures are addressed below:

Table 3: Mitigation measures Environmental categories


Mitigation measure proposed


Conserve the diversity of habitats and protected species

All renewable energy projects proposed will individually be assessed against the requirements of the Environmental Impact Assessment (EIA) Guidelines and the Birds and Habitats Directive and through the EIA and Appropriate Assessment process will be required to demonstrate that they will not have an adverse impact on any Natura 2000 sites or site otherwise designated before they will be permitted to proceed. It is recommended that the RES set out policy with respect the appropriate protection of designated sites and the environment through the EIA, SEA and AA processes.


• Promote sustainable water use based on long-term protection of available water resources.

• Protect and enhance the status of aquatic ecosystems and, with regard to their water needs, terrestrial ecosystems and wetlands directly depending on the aquatic ecosystems.

Large scale proposals for processing and energy infrastructure will be subject to the planning process. Key to this process will be an assessment of the environmental suitably of any site for the development proposed. The Planning Authority will consult with the EPA and the Department of the Environment along with the other statutory bodies to ascertain whether a development would have an acceptable impact on the environment. This Environmental Report has examined the full range of environmental parameters applicable to the development of renewables and in Section 7.3 of the RES sets out the policy of the Council with respect the development of renewable energy projects, this policy will guide and inform the general public and developers alike with respect the suitability of any site for renewable energy development in South Tipperary.


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Conserve and enhance valued natural and historic landscapes and features within them.

The South Tipperary Wind Energy Strategy was incorporated into planning policy as part of the County Development Plan in 2006. The Wind Energy Strategy has provided for the sustainable development of the county wind energy resources since its adoption and it is considered that the current wind energy strategy should be maintained with no change until the next review of the RES in 2020. The county wind energy development areas are set out in Appendix 3. In applying the Wind Energy policy of the County Development Plan, the Council will actively encourage developers and investors to engage with local communities to ascertain their concerns with respect new development, to undertake to address these concerns where feasible and to consider the setting up of appropriate community funds or schemes that will help to confer a gain to the local community in areas where it is proposed to install largescale renewable energy developments. In applying the Wind Energy policy of the County Development Plan, the Council will actively encourage developers and investors to consider the cumulative impact of wind energy development in areas where wind developments have already been permitted. Reference in this respect may be made to the Wind Energy Guidelines 2006 and to the Scottish Natural Heritage Guidelines - Assessing the Cumulative Impact of on-Shore Wind Energy Developments 2012.


• Reduce all forms of air pollution.

Minimise emissions of greenhouse gases to contribute to a reduction and avoidance of human-induced global climate change.

Reduce waste of

All renewable energy projects proposed will be individually assessed against the requirements of the Environmental Impact Assessment (EIA) Guidelines and the Birds and Habitats Directive and through the EIA and Appropriate Assessment process will be required to demonstrate that they will not have an adverse impact on air and climate before they will be permitted to proceed.


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energy, and maximise use of renewable energy resources.

• Assess, plan and manage adaptation to climate change impacts.

Material Assets • Maximise the

use of the existing built environment.

• Avoid flood risk and / or coastal erosion in selecting sites for development.

It is recognised that renewable energy infrastructure cannot always be located on lands that is zoned for industry and employment and in certain cases i.e. in the case of the development of farm based anaerobic digestion facilities will be developed outside of zoned areas. This is recognised. However, for very large scale processing facilities the council will give careful consideration to the ability of the site to accommodate new development, important considerations will be impact on infrastructure, water quality, human health etc. Traffic Impact Assessment may be required as appropriate. The minimisation of flood risk continues to be an important consideration of the Council and in assessing any planning application the planning authority will have consideration to flood risk potential. Flood risk mapping as currently available and that will be available through the OPW CFRMPS will be applied. Flood Risk Assessment may be required where appropriate

9.0 Monitoring Proposals The purpose of environmental monitoring is to help in the ascertainment of the success of the implementation of the plan and the impact of plan implementation on the receiving environment. Environmental monitoring of the effects of the implementation of the County Development Plan and each of the town Development Plans is carried out on an annual basis. The monitoring programme is detailed and assessed the impacts of new development on the baseline environment of the county and considers key issues such as water quality, air quality, built and natural environment etc. Environmental monitoring for the RES will be incorporated into the existing monitoring programme; however, it is proposed that in addition to the existing monitoring targets, that additional monitoring objectives that relate to


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the development of the renewable energy industry should be incorporated into the County Development Plan monitoring programme. The following three monitoring objectives shall be carried out in addition to the annual environmental monitoring prepared for the County Development Plan. The critical issues for monitoring are set out below:

1. Development of Wind Energy.

It is proposed that the number of grid connected wind turbines in the county be measured annually, and also the total energy (kW) produced by the grid connected turbines should be noted. This process may be carried out by the Local Authority.

2. Energy output by County

The total production of energy in the county from renewable resources should be monitored annually. This process shall be carried out by TEA, and energy produced from renewable resources should be compared against total county energy demand.

3. Development of Anaerobic Digestion at the farm scale.

It is recommended that the number of grid connected farm scale anaerobic digester facilities be recorded annually to determine the update of farm scale AD facilities in the county. The may be carried out by the planning authority through the IPlan system.


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Appendix 1 : Slievenamon Bog SITE NAME: SLIEVENAMON BOG NHA SITE CODE: 002388 Slievenamon Bog NHA consists primarily of upland blanket bog and is located approximately 10 km north-west of Carrick-on-suir, Co. Tipperary. The site is situated within fifteen different townland areas, including Ballyknockane, Ballypatrick, Brenormore, Tober, Killusty North, Killavally, and Killurney. The mountain ranges in altitude from 300 m to 721 m and it stands as an isolated feature, surrounded by the low-lying landscape of South Tipperary. Granites and sandstones form the underlying geology. The site is bordered on much of its northern and its southern side by forestry plantation, where obvious trackways separate the bog site from the plantations. Along the eastern and western side, farmland forms the boundaries. Streams on the eastern side drain into the Lingaun River that joins the River Suir in Carrick-on-Suir. Streams on the northern and western slopes drain into the Anner River that joins the River Suir outside Clonmel. The site contains a good example of a mountain blanket bog. It contains a mosaic of vegetation types, including mountain blanket bog, headwater bogs, wet saddle bogs, dry heath, wet heath, flushes, acid grassland and vegetated, river gorges. Peat is shallow over much of the mountain’s slopes but deeper peat has accumulated at the base of slopes and at the headwaters of the streams that drain the mountain. Rocky outcrops occur on the summits of Carrignagun and Carrickabrock. At the base of the slopes and at the headwaters of the rivers where deep peat has accumulated the vegetation consists of Ling Heather (Calluna vulgaris), Hare’s-tail Cottongrass (Eriophorum vaginatum) and Deergrass (Scirpus caespitosus). Additional species include Common Cottongrass (Eriophorum angustifolium), Purple Moor-grass (Molinia caerulea), Cross-leaved Heath (Erica tetralix), Heath Milkwort (Polygala serpyllifolia), Tormentil (Potentilla erecta), Round-leaved Sundew (Drosera rotundifolia) and Carnation Sedge (Carex panicea). The moss Campylopus atrovirens is also found in these areas. Dense carpets of bog mosses are common, with Sphagnum capillifolium, S. papillosum, and S. subnitens occurring as low hummocks in wetter areas and Sphagnum recurvum occurring in flushed areas. Moss species, Polytrichum commune, is also common. In general, bog pools are not common on the site, but on the saddle area between Carricagun and Carrickabrock, water has accumulated between outcropping rocks. Wet heath is more common on the northern sides of the mountain. Ling Heather grows up to 60 cm tall and in association with Deergrass, Cross-leaved Heath and Tormentil. Sedges include Common Sedge (Carex nigra), Star Sedge (C. echinata), and Green-ribbed Sedge (C. binervis) while grasses Sweet Vernal-grass


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(Anthoxanthum odoratum) and Mat-grass (Nardus stricta) also occur. On the southern slopes of Slievenamon, a drier heath vegetation has developed with characteristic species including short, Ling Heather, Bell Heather (Erica cinerea), Wavy Hair-grass (Deschampsia flexuosa), Bilberry (Vaccinium myrtillus) and Heath Rush (Juncus squarrosus). A deep, river gorge cuts through the slopes on the southern side of the mountain, adding further habitat diversity to the site. The steep, clay sides of the gorge support an open woodland and heath-type vegetation, with Bracken (Pteridium aquilinum), Ling Heather, Bilberry, Rowan (Sorbus aucuparia), willows (Salix sp.), oaks (Quercus spp.), birches (Betula spp.) and Rhododendron (Rhododendron ponticum). The trees have an extensive cover of lichens, indicating a pollution-free environment, and there is a rich carpet of mosses and liverworts beneath the trees. The site hosts a range of bird species including Skylark, Meadow Pipit, Raven, and Kestrel. A range of butterfly and moth species also occur including the Oak Eggar, Yellow Underwing, Small White, Common Blue, Peacock, Red Admiral, Meadow Brown, Ringlet and a species of Fritillary. The Irish Red Data Book species, Common Frog, also occurs here. Most of the site shows evidence of disturbance from burning and grazing. Damage on the generally drier southern slopes has resulted from heavy grazing pressure and burning, with evidence of both old and recent fire events. Both activities result in erosion of the peat structure and a change in bog vegetation to more open, acid grassland. In addition, a roadway was recently excavated on the southern slopes, with the expectation of installing wind turbines. While this plan was rejected at the time, the road is now a popular amenity with hill walkers, posing the possible threat of further degradation to the slopes. Also, as commercial plantations border much of the site, a potential threat is the possible expansion of forestry. Slievenamon Bog NHA is a site of considerable conservation significance. It contains a good example of upland blanket bog. The site is reasonably diverse in terms of species and communities due to local variation. Blanket bog habitat is a globally scarce resource. It is largely confined to coastal regions at temperate latitudes with cool, wet, oceanic climates. North-west Europe contains some of the best-developed areas of blanket bog in the world. The most extensive areas are found in Ireland and Britain. Upland blanket bogs, due to their exposure to severe climatic conditions at high elevations, are particularly vulnerable to erosion by human activities and extensive areas are currently undergoing active erosion due mainly to overgrazing. The current area of intact upland blanket bog in Ireland represents only a fraction of the original resource, due to the combined impacts of afforestation and overgrazing, and intact examples are therefore extremely valuable for nature conservation. Their long-term survival requires sensitive management.


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S.I. No. 499 of 2005: Natural Heritage Area (SLIEVENAMON BOG NHA 002388) Order 2005 The Minister for the Environment, Heritage and Local Government, in exercise of the powers conferred on him by section 18 of the Wildlife (Amendment) Act 2000 (No. 38 of 2000) (as adapted by the Environment and Local Government (Alteration of Name of Department and Title of Minister Order 2003 (S.I. No. 233 of 2003))), having complied with section 16 of that Act and after considering any objections made in relation to the relevant notice served under section 16(2)(b) of that Act hereby orders as follows: 1. This Order may be cited as the Natural Heritage Area (Slievenamon Bog NHA

002388) Order 2005 and comes into operation on 27th July 2005. 2. In this Order “Act” means the Wildlife (Amendment) Act 2000 (No. 38 of

2000). 3. The area of land comprising that part of Slievenamon Bog in the townlands of

Ballyknockane, Ballypatrick, Boherboy, Boolagh, Brenormore, Cappadrummin, Cloran New, Cloran Old, Glennaskagh, Graigue (Ed Kilcash), Gurtnapisha, Killavally, Killurney, Killusty North, Killusty South, Knockanclash, Lisnatubbrid, Shanbally (Ed Kilcash), Tinnakilly (Ed Cloneen), Tober, Toor and Walshsbog in the County of Tipperary (being the land enclosed on the map (contained in Schedule 1 to this Order) within the inner margin of the green line and hatched thereon in green) is designated a natural heritage area.

4. (1) Subject to sub-article (2) of this article, each of the works mentioned in

Schedule 2 is specified for the purposes of section 19(1) of the Act and is unlawful unless carried out with the consent of the Minister.

(2) In respect of the works specified at paragraphs 19 to 22 of Schedule 2, there is no requirement to obtain the consent of the Minister if the said works are licensed by, or subject to the permission of another Minister or Public Body.

Schedule 2 Works specified for the purposes of section 19 (1) of the Act. 1. Cutting turf except from existing banks; cutting intact (uncut) areas. 2. Commercial peat moss or turf extraction, or use of ‘sausage’ machines. 3. Drainage works or water abstraction affecting the hydrology of the site. 4. Alteration of the banks, bed or flow of a lake, pond or watercourse, within

the site, or causing siltation. 5. Burning areas of vegetation. 6. Reclamation, in-filling, ploughing or other cultivation. 7. Reseeding, planting of trees or any other species. 8. Cutting trees, scrub, reeds; removal of timber or other vegetation.


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9. Dumping, burning or storing any materials. 10. Any activity that may cause pollution or nutrient increase/eutrophication,

including aerial deposition of fertilizers or chemicals. 11. Adding lime or fertilizer to previously untreated areas. 12. Introduction (or re-introduction) into the wild of plants or animals of species

not currently found in the area. 13. Supplementary feeding of stock, except where permitted in farm plans or

prescriptions under the Rural Environment Protection Scheme or other Government approved agricultural and/or environmental schemes.

14. Grazing of livestock above a recommended density and period (as defined in farm plans or prescriptions under the Rural Environment Protection Scheme or other Government approved agricultural and/or environmental schemes).

15. Use of any pesticide or herbicide, including sheep dip. 16. Any activity likely to cause increased risk of erosion or destabilisation of the

peat deposit (e.g. use of quad bikes), or likely to damage vegetation cover or interfere with the hydrological condition of the site.

17. Deliberate scaring or disturbance of wildfowl. 18. Stocking pools, ponds, lakes or rivers with fish. 19. Operation of commercial recreational activities. 20. Removal of rock, soil, mud, gravel, sand or minerals. 21. Creation or improvement of tracks, paths, roads, car parks or other

infrastructure. 22. Construction of fences or embankments.


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Appropriate Assessment 1.0 Methodology This is the Natura Impact Assessment (NIA) prepared as part of the Appropriate Assessment (AA) of the South Tipperary Renewable Energy Strategy 2014 (RES), it has been prepared in accordance with the ‘Appropriate Assessment of Plans and Projects in Ireland’ – Guidance for Planning Authorities 2010, published by the Department of Environment, Heritage and Local Government. The requirement to undertake AA derives from Article 6(3) and 6(4) of the Habitats Directive and the purpose of the process is to, through transparent decision making processes, ensure that new development will not have an adverse impact on any Natura 2000 site. Any plan or project that will have an adverse impact on a Natura 2000 site will only be permitted if it can be demonstrated that it is of overriding public interest and thus must proceed. The following methodology is applied to this NIA:

1 Methodology

2 Relationship of AA with SEA

3 Screening and Scoping process

4 Consultation with the Department of Arts Heritage and the Gaeltacht.

5 Natura Impact Statement (NIS)

5.1 Description of Natura 2000 site network and the Conservation Objectives

5.2 Describe the likely significant impacts on the Natura 2000 site network

5.3 Describe any mitigation measures to prevent, reduce and as fully as possible offset any significant adverse environmental effects of implementing the plan

6 AA Conclusion Statement

Appendix

Map of SACs and SPAs


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2.0 Relationship of AA with Strategic Environmental Assessment The Strategic Environmental Assessment (SEA) is set out in Appendix 4 of the RES along with the AA. There are clear links and analogies between the AA and the SEA. They are parallel but separate processes that overlap but also differ in some key respects. The focus of this AA is on the impacts of the RES on the integrity of Natura 2000 sites and the Natura 2000 network. In contrast, SEA assists in formulating plan policies and objectives that provide for a more strategic level of protection of the environment in general. Nonetheless both SEA and AA contribute to the integration of environmental considerations in the adoption of a plan and promote sustainable development. The three main inter-relationships between AA and SEA are:

• AA is a tool that assists in addressing environmental issues as part of the SEA in relation to Natura 2000 sites.

• AA assists the SEA process in the systematic and explicit appraisal of alternatives in relation to Natura 2000 sites.

• Undertaking AA in parallel with SEA provides for an efficient use of resources and expertise. Both processes benefit each other’s findings.

3.0 Screening and Scoping Processes 3.1 Screening Screening for AA commenced with the preparation of the RES Issues Paper. The planning authority determined and identified existing and potential effects of the plan on the Natura 2000 site or network. To facilitate this process an AA screening report and determination was prepared and issued to the National Parks and Wildlife Service in February 2013. There are two possible outcomes to the screening process:

• the plan poses no risk of a significant effect and as such requires no further assessment; and

• the plan has potential to have a significant effect (or this is uncertain) and AA of the plan is necessary.

It was determined by South Tipperary County Council that the implementation of the Plan may have an impact on the Natura 2000 site network and therefore, AA was required.


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3.2 Scoping The purpose of scoping is to identify more precisely what the AA must cover, including the data, information and level of detail required in the NIS. In this way, scoping helps at the early stages of plan preparation to reduce the possibility of relevant issues not being identified. Neither the Habitats Directive nor EU guidance provides explicit guidance in relation to the scope and the level of detail to be included in the AA conclusion report. The word ‘appropriate’ is key in that the assessment must be appropriate to the Natura 2000 site, its conservation objectives and sensitivities, and to the level of detail that the AA must be conducted at, having taken cognisance of the position of the plan within the hierarchy of plans, and its potential impacts on the conservation objectives of Natura 2000 sites, taking existing conditions and issues into account. It is recommended that at the end of the scoping procedure, the plan-making authority should prepare a brief scoping report of its conclusions as to what information is to be included in the NIS, taking account of any recommendations from various statutory bodies. The National Parks and Wildlife Service (NPWS) ensures designated sites are protected from significant damage through consultation and discussions with landowners. However the local authority regulates and controls development within its functional area and therefore a potential exists to adversely impact on Natura 2000 sites through inappropriate development either within or close to designated sites. Such development either in isolation or in combination with other similar developments can potentially lead to significant adverse impacts on the environment with long term consequences. It is likely that the implementation of the RES may lead to and facilitate the following key areas of development with the potential to impact on Natura 2000 sites: Table 1: Development with the potential to impact on Natura 2000 sites All forms of Micro renewable energy resource collectors – Private wind turbines, solar panels, private combined heat and power units, small scale anaerobic digestion etc. Macro Renewable forms Commercial Hydropower – Development of upland hydropower facilities to generate electricity from stored water, development of lowland water resources through impoundment or diversion. Commercial Bio-Energy – Anaerobic digestion facilities at the medium to large scale, bio fuel production facilities etc Commercial Wind Energy – Wind turbines on upland areas and individual turbines developed on sites to provide for the energy needs of enterprise and industry. Bio-Energy Cropping – Growth of crops for production of energy i.e. willow,


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miscanthus, sugar beet, oilseed rape etc. Commercial Geothermal Units – Large scale geothermal collectors Commercial Solar Units – large scale photovoltaic or solar collectors

4.0 Consultation with the National parks and Wildlife Service (NPWS) It is the recommendation of the planning authority that AA is required for the preparation of this RES. In February 2013, the planning authority carried out the following:

• Made a copy of its decision, including, as appropriate the reasons for requiring an AA, available for public inspection at the offices of the planning authority during office hours.

• Notified its decision to the NPWS as part of the AA Scoping Process for the Plan.

Thereafter, the Draft RES and NIA were made available for the further consideration of the NPWS and the other statutory environmental authorities. All comments received were considered during the preparation of this final RES.

5.0 Baseline Environment 5.1 Special Areas of Conservation (SACs) and Special Protection Areas

(SPAs) SACs are prime wildlife conservation areas in the country, considered to be important on a European as well as Irish level. The legal basis on which SACs are selected and designated is the EU Habitats Directive (92/43/EEC), transposed into Irish law in the European Union (Natural Habitats) Regulations, 1997. The Directive lists (Annex I) certain habitats that must be protected within SACs. Irish habitats include raised bogs, blanket bogs, turloughs, sand dunes, machair (flat sandy plains on the north and west coasts), heaths, lakes, rivers, woodlands, estuaries and sea inlets. There is also a list (Annex II) of species, which must be afforded protection, and for Ireland this includes the Bottle-Nosed Dolphin, Otter, Freshwater Pearl Mussel and Killarney Fern. The EU Birds Directive provides for a network of sites (Special Protection Areas – SPAs) in all Member States to protect birds at their breeding, feeding, roosting and wintering areas. It identifies species which are rare, in danger of extinction or vulnerable to changes in habitat and which need protection.


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Figure 1 below outlines the location of all Natura 2000 sites in South Tipperary and the features of Interest for each site are listed in Table 1 below. A more detailed illustration of the sites is set out in the attached appendix.

Figure 15: Location of Natura 2000 Sites

Table 2: Features of Interest of Natura 2000 sites in South Tipperary Galtee Mountains SAC (000646) European dry heaths [4030] Alpine and Boreal heaths [4060] Species-rich Nardus grasslands, on siliceous substrates in mountain areas (and submountain areas, in Continental Europe) [6230] Blanket bog (*active only) [7130] Calcareous rocky slopes with chasmophytic vegetation [8210] Siliceous rocky slopes with chasmophytic vegetation [8220]

Philipston Marsh SAC (001847) Transition mires and quaking bogs [7140] Alkaline fens [7230]

Anglesey Road SAC (002125) Species-rich Nardus grasslands, on siliceous substrates in mountain areas (and

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submountain areas, in Continental Europe) [6230]

Lower River Suir SAC (002137) Freshwater pearl mussel (Margaritifera margaritifera) [1029] White-clawed crayfish (Austropotamobius pallipes) [1092] Sea lamprey (Petromyzon marinus) [1095] Brook lamprey (Lampetra planeri) [1096] River lamprey (Lampetra fluviatilis) [1099] Allis shad (Alosa alosa) [1102] Twaite shad (Alosa fallax fallax) [1103] Salmon (Salmo salar) [1106] Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] Otter (Lutra lutra) [1355] Mediterranean salt meadows (Juncetalia maritimi) [1410] Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260] Hydrophilous tall herb fringe communities of plains and of the montane to alpine levels [6430] Old sessile oak woods with Ilex and Blechnum in British Isles [91A0] Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0] Taxus baccata woods of the British Isles [91J0]

River Barrow and River Nore SAC (002162) Vertigo moulinsiana [1016] Freshwater pearl mussel (Margaritifera margaritifera) [1029] White-clawed crayfish (Austropotamobius pallipes) [1092] Sea lamprey (Petromyzon marinus) [1095] Brook lamprey (Lampetra planeri) [1096] River lamprey (Lampetra fluviatilis) [1099] Allis shad (Alosa alosa) [1102] Twaite shad (Alosa fallax fallax) [1103] Salmon (Salmo salar) [1106] Estuaries [1130] Mudflats and sandflats not covered by seawater at low tide [1140] Salicornia and other annuals colonizing mud and sand [1310] Spartina swards (Spartinion maritimae) [1320] Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] Otter (Lutra lutra) [1355] Mediterranean salt meadows (Juncetalia maritimi) [1410] Killarney fern (Trichomanes speciosum) [1421] Pearl mussel (Margaritifera durrovensis) [1990] Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260] European dry heaths [4030] Hydrophilous tall herb fringe communities of plains and of the montane to alpine levels [6430]

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Petrifying springs with tufa formation (Cratoneurion) [7220] Old sessile oak woods with Ilex and Blechnum in British Isles [91A0] Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0]

Blackwater River (Cork/Waterford) SAC (002170) Freshwater pearl mussel (Margaritifera margaritifera) [1029] White-clawed crayfish (Austropotamobius pallipes) [1092] Sea lamprey (Petromyzon marinus) [1095] Brook lamprey (Lampetra planeri) [1096] River lamprey (Lampetra fluviatilis) [1099] Allis shad (Alosa alosa) [1102] Twaite shad (Alosa fallax fallax) [1103] Salmon (Salmo salar) [1106] Estuaries [1130] Mudflats and sandflats not covered by seawater at low tide [1140] Perennial vegetation of stony banks [1220] Salicornia and other annuals colonizing mud and sand [1310] Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] Otter (Lutra lutra) [1355] Mediterranean salt meadows (Juncetalia maritimi) [1410] Killarney fern (Trichomanes speciosum) [1421] Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260] Old sessile oak woods with Ilex and Blechnum in British Isles [91A0] Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0] Taxus baccata woods of the British Isles [91J0]

Site Name: Moanour Mountain SAC (002257) Species-rich Nardus grasslands, on siliceous substrates in mountain areas (and submountain areas, in Continental Europe) [6230] Site Name: River Barrow and River Nore SAC (002162) Vertigo moulinsiana [1016] Freshwater pearl mussel (Margaritifera margaritifera) [1029] White-clawed crayfish (Austropotamobius pallipes) [1092] Sea lamprey (Petromyzon marinus) [1095] Brook lamprey (Lampetra planeri) [1096] River lamprey (Lampetra fluviatilis) [1099] Allis shad (Alosa alosa) [1102] Twaite shad (Alosa fallax fallax) [1103] Salmon (Salmo salar) [1106] Estuaries [1130] Mudflats and sandflats not covered by seawater at low tide [1140] Salicornia and other annuals colonizing mud and sand [1310] Spartina swards (Spartinion maritimae) [1320] Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330]

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Otter (Lutra lutra) [1355] Mediterranean salt meadows (Juncetalia maritimi) [1410] Killarney fern (Trichomanes speciosum) [1421] Pearl mussel (Margaritifera durrovensis) [1990] Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260] European dry heaths [4030] Hydrophilous tall herb fringe communities of plains and of the montane to alpine levels [6430] Petrifying springs with tufa formation (Cratoneurion) [7220] Old sessile oak woods with Ilex and Blechnum in British Isles [91A0] Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0] Site Name: Lower River Shannon SAC (002165) Freshwater pearl mussel (Margaritifera margaritifera) [1029] Sea lamprey (Petromyzon marinus) [1095] Brook lamprey (Lampetra planeri) [1096] River lamprey (Lampetra fluviatilis) [1099] Salmon (Salmo salar) [1106] Sandbanks which are slightly covered by sea water all the time [1110] Estuaries [1130] Mudflats and sandflats not covered by seawater at low tide [1140] Coastal lagoons [1150] Large shallow inlets and bays [1160] Reefs [1170] Perennial vegetation of stony banks [1220] Vegetated sea cliffs of the Atlantic and Baltic coasts [1230] Salicornia and other annuals colonizing mud and sand [1310] Spartina swards (Spartinion maritimae) [1320] Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] Bottle-nosed dolphin (Tursiops truncatus) [1349] Otter (Lutra lutra) [1355] Mediterranean salt meadows (Juncetalia maritimi) [1410] Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260] Molinia meadows on calcareous, peaty or clavey-silt-laden soils (Molinion caeruleae) [6410] Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0]

Special Protection Areas: Slievefelim to Silvermines Mountains Site Code: 004165 The Slievefelim to Silvermines Mountains SPA is an extensive upland site located in Counties Tipperary and Limerick. Much of the site is over 200 m in altitude and rises to 694 m at Keeper Hill. The site consists of a variety of upland habitats, though

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approximately half is afforested. The principal tree species present are Sitka Spruce (Picea sitchensis) and Lodgepole Pine (Pinus contorta). Roughly one-quarter of the site is unplanted blanket bog and heath, with both wet and dry heath present. The remainder of the site is mostly rough grassland that is used for hill farming. The site is of special conservation interest for the Hen Harrier. This SPA is one of the strongholds for Hen Harrier in the country. A survey in 2005 resulted in four confirmed breeding pairs and one possible breeding pair, whereas nine pairs had been recorded in the 1998-2000 period. These numbers represent 3% of the national total. The site is also a traditional breeding site for a pair of Peregrine. Red Grouse are found on some of the unplanted areas of bog and heath. The main threat to the long-term survival of Hen Harriers within the site is further afforestation, which would reduce and fragment the area of foraging habitat, resulting in possible reductions in breeding density and productivity. Overall, the site provides excellent nesting and foraging habitat for breeding Hen Harrier and is among the top five sites in the country for the species.

5.2 Assessment of Natura 2000 sites. Natura 2000 sites in South Tipperary are primarily associated with upland and mountains areas including - the Galtee Mountains, Maonour Mountain, Slievephelem and Slivermines Mountains and Anglesea Road, and with aquatic environments. In general the sites are transboundary and extend into the adjoining counties. The only sites that are contained entirely within South Tipperary are Anglesea Road, Moanour Mountain and Philipstown Marsh. The River Suir SAC is a major influencing factor on the environmental character of the county. The River Suir SAC extends along the river Suir in a north to south direction through the centre of the county and then turns north and east where the Suir flows from Clonmel, to Carrick-on-Suir and onwards to Waterford. It major tributaries are the Lingaun (east), Anner and Moyle (north east), Tar (south), Aherlow (west) and Multeen (north), these extend across the entire county. Water quality on the Suir and its tributaries are a major indicator of environmental quality in South Tipperary. The most recent complete report on water quality was published by the EPA in 2011 and is entitled ‘Report on River Water Quality in South Tipperary 20116

’ this sets out water monitoring results for 6 parameters including– ammonium, BOD, dissolved oxygen, o-phosphate, pH, o-phosphate and total oxidised nitrogen.

It is illustrated that in South Tipperary there were 17 sites with a Q value of less than good status (3-4 or less). There are up to three suspected causes of pollution listed for each site. Roughly 50% are polluted due to point sources and 50% due to diffuse

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sources. The EPA report also addresses physio-chemical water quality in the county and areas where water quality have changed and potential sources for change. Based on this data (water quality and assimilative capacity) it is possible to determine where surface water is most vulnerable to deterioration as a result of change in its catchment. It is also possible to determine where water bodies are most robust in terms of their capacity to accommodate extraction or discharge as a result of new development. Through an evaluation of the sites conservation status from information obtained from the NPWS, the principal threats to the long term conservation of the sites as a result on the development of renewable energy in the county can be summarised as the following: • Disturbance to habitats including aquatic and upland; • Afforestation/changing crop practices • Water Quality Change, including change to water quality and abstraction. Impacts can occur either in isolation or in combination with other impacts and can potentially led to significant adverse impacts on the environment with long term consequences.

5.3 Describe the likely significant impacts on the Natura 2000 site network The conservation objectives for each of the Natura 2000 sites are provided below. The objectives are based on the overall conservation value of the individual sites. Conservation Objectives: Special Areas of Conservation Site Code: 000646 Galtee Mountains To ensure there is no net loss of area or change to the structure, biodiversity or distribution pattern of the highly sensitive communities within the site. To ensure the legal protection of those plant species protected under the Flora Protection Order (1987). Site Code: 001847 Philipston Marsh To ensure there is no net loss of area or change to this transition mire, it’s abundant marl plant community and biodiversity. Site Code: 002125 Anglesey Road To ensure there is no net loss of area or change to the unimproved upland grassland (Annex I habitat); its structure and its microhabitats. Site Code: 002137 Lower River Suir To ensure there is no net loss of area or change to the structure, biodiversity or distribution pattern of the highly sensitive communities within the site. To ensure the conservation of Annex I habitats and Annex II species present. To ensure the legal protection of those plant species protected under the Flora Protection Order (1987) and to protect species found within the Red Data Book of threatened species.


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Site Code: 002162 River Barrow and River Nore To ensure there is no net loss of area or change to the structure, biodiversity or abundance of various habitats within the site. To ensure the legal protection of those plant species protected under the Flora Protection Order (1987). To ensure the conservation of Annex I habitats and Annex II species present and to protect species found within the Red Data Book of threatened species. Site Code: 002165 Lower River Shannon To ensure there is no net loss of area or change to the structure, biodiversity or distribution pattern of the highly sensitive communities within the site. To ensure the conservation of Annex I habitats and Annex II species present. To protect species found within the Red Data Book of threatened species. Site Code: 002170 Blackwater River To ensure there is no net loss of area or change to the structure or biodiversity within the site. Site Code: 002257 Moanour Mountain To ensure there is no net loss of area or change to the Annex I habitat, the Nardus grassland, its abundant plant community and biodiversity. Special Protection Areas Site Code: 0004165 Slievefelim to Silvermines Mountains To ensure there is no net loss of area or change to the structure or biodiversity within the site and the retention and protection of the nationally important bird species (Hen Harrier, Peregrine, Merlin and Red Grouse). The Guidelines recommend that an integrity Checklist be prepared to assess the potential for impact on the integrity of sites, this is presented below. It was found that the implementation of the Plan had the potential to impact on Natura 2000 sites under the headings set out. Table 3: Integrity of site checklist (from AA Guidelines Box 10) Conservation Objectives Does the project or plan have the potential to: Yes/No/Unknown Cause delays in progress towards achieving the conservation objectives of the site?

No

Interrupt progress towards achieving the conservation objectives of the site?

No

Disrupt those factors that help to maintain the favourable conditions of the site?

Yes

Interfere with the balance, distribution and density of key species that are the indicators of the favourable condition of the site?

Yes


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Other objectives: does the project or plan have the potential to:

Cause changes to the vital defining aspects (e.g. nutrient balance) that determine how the site functions as a habitat or ecosystem?

Yes

Change the dynamics of the relationships (between, for example, soil and water or plants and animals) that define the structure and/or function of the site?

Yes

Interfere with predicted or expected natural changes to the site (such as water dynamics or chemical composition)?

Yes

Reduce the area of key habitats? Yes Reduce the population of key species? Yes Change the balance between key species? Yes Reduce diversity of the site? Yes Result in disturbance that could affect population size or density or the balance between key species?

Yes

Result in fragmentation? Yes Result in loss or reduction of key features (e.g. tree cover, tidal exposure, annual flooding, etc.)?

Yes

In conclusion it can be shown, using the precautionary principle, that the implementation of the RES has the potential to adversely impact on the integrity of the Natura 2000 sites. The potential exists to;

• reduce the area of Natura 2000 sites by loss or fragmentation through inappropriate or insensitive development;

• cause fundamental and deleterious changes in the chemistry of the soil and water environment;

• interfere with water flows and flood dynamics; and • create unnecessary disturbance through inappropriate development with

adverse effects on fauna species.

5.4 Describe any mitigation measures to prevent, reduce and as fully as possible offset any significant adverse environmental effects of implementing the plan The RES is not a statutory document and its function is to inform the development of policies and objectives of the County Development Plan. The preparation of the RES has incorporated both AA and SEA and has been developed with the protection of the environment in mind. The next step for the RES will be the incorporation of the objectives and targets of the RES into the County Development Plan with it is reviewed or varied. It is recommended that any policies incorporated into the County Development Plan in support of the Renewable Energy industry, reflect the requirements of Article 10 and the Habitats Directive and set out a framework that will ensure that designated sites are protected. The following policy approach is to be incorporated:


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• It is a policy of the Council to conserve and protect the ecological integrity of designated sites of international and national importance, and sites proposed for designation, in particular, European sites (including Natura 2000 sites), and Ramsar sites, NHAs and statutory nature reserves.

• Where proposed renewable energy related development has the potential for significant impacts on Natura 2000 sites, it is a policy of the Council to require the submission of a Natura Impact Assessment (NIS) at planning application stage to enable the planning authority carry out Appropriate Assessment (AA) of the proposed development. If it can be concluded on the basis of AA that there will be no adverse effects on the integrity of a Natura 2000 site, the project can proceed to authorisation, where the normal planning or other requirements will apply in reaching a decision to approve or refuse planning permission. If adverse effects are likely, or in cases of doubt, the derogation steps of Article 6(4) of the Habitats Directive will apply, but only in a case in which there are imperative reasons of overriding public interest (IROPI) requiring a project to proceed, there are no less damaging alternative solutions, and compensatory measures have been identified that can be put in place.

6.0 AA Conclusion Statement 1. Summary of how the findings of AA were factored into the Plan:

The RES incorporates a recommendation that the policy objectives as outlined above be incorporated into statutory planning policy with respect the development of renewable energy in the county that has the potential to impact on designated sites. This will have the affect of ensuring that all projects submitted to the planning authority will be screened for their potential to impact on designated sites.

2. Reasons for choosing the plan as adopted, in light of other reasonable

alternatives considered. The achievement of binding national targets for the use of renewable energy

as an alternative to the consumption of fossil fuels is the main reason for the decision of South Tipperary County Council to develop this RES. It is the decision of the Council chose to support the development of renewable energy through a multi-faceted approach that supports the development of all renewable energy resources rather than any one resource at the exclusion of others, subject to the protection of the environment.

3. A declaration that the plan as adopted will not have an adverse effect on the

integrity of a Natura 2000 site. South Tipperary County Council is satisfied that the implementation of the

RES will not have an adverse impact on any designated sites having consideration to the mitigation measures and controls proposed.


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APPENDIX

A) Map of SACs

B) Map of SPAs

Special Areas of Conservation

Natural Heritage Areas

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