Dear Minister,
In response to the consultation on proposed revisions to the wind energy development guidelines 2006 –I would like to submit the following:
In response to the consultation on proposed revisions to the wind energy development guidelines 2006 –I would like to submit the following:
1.
When assessing setback as a noise control
method, I would discard the assessment of ground cover types. Ground cover can
and probably will change many times in the lifetime of a windfarm. If a
forestry exists today to shield a home from excessive noise, this could be
felled within 12 months and returned to pasture. Likewise, a home sheltered by
trees, could lose them all in a storm or to disease. It is not permanent enough
to assess noise.
2.
The proposed minimum separation of 500m for
amenity considerations is too static. Current minimum distance requirements
have been left behind by the rapid inflation in the size of wind turbines over
the period. Rather, the minimum separation should be a multiple of the height
of the turbine. This is already the case in other jurisdictions.
Personally, I believe the minimum distance
should be quite high and I would like to see a minimum separation of at least ten
times the height of the wind turbine. In the recently rejected planning
application for a windfarm development in Cloghan, Co. Offaly, the inspector
deemed that the proposal for 170 metre tall wind turbines would excessively
dominate the landscape as viewed from 34 houses in a 1200m radius. This equalled
a distance ratio of 7 times the height of the wind turbines. However, it should
be remembered that this development was deemed unacceptably obtrusive and I
believe we should therefore implement a minimum distance that is generously in
excess of this. Therefore, a distance of ten times the height of the turbine
seems reasonable to me.
Furthermore, this will give more
opportunities to more moderately sized developments, while keeping the really
enormous projects away from habitation.
3.
I believe the definition of a noise sensitive
property should include all buildings in which the same people are compelled to
spend a significant amount of time. This should include fixed places of work
-even without permanent structures.
4.
I note that the 40dba noise limit is considered
to be at the lower end of the scale internationally. However, I believe it
should be exceptionally low. Ireland has a dispersed settlement pattern and
will generally have many more people effected by windfarm noise than in other
countries. We should be international leaders in this regard.
5.
In
assessing noise at preconstruction stage, the windspeed used to assess noise
output should be at hubheight –not groundspeed.
6.
There is also an issue which I believe should
also pertain to proximity and which is not listed in the consultation document.
Proximity to household watersources should be a factor in assessing wind
turbine developments. The deep foundations required for windturbines inevitably
interferes in watersources. Where householders are depending on watersources in
the vicinity, this should be a factor in granting permission for development.
7.
Finally, though not mentioned in the document,
visual impact of windturbines should be considered in their own right, in
accordance with the Offaly decision.
Sincerely