Bord na Móna Renewable Energy Sources

Unique Reference Number: 
WM-C1-87
Status: 
Submitted
Author: 
Bord na Móna
No. of documents attached: 
1
Boundaries Captured on Map: 
No
Author: 
Bord na Móna

Cover Letter

Bord na Móna welcomes the opportunity to make a submission in relation to the Draft Westmeath County Development Plan 2021 - 2027.

Since its foundation Bord na Móna has been part of the socio-economic and cultural fabric of County Westmeath. The company has contributed to economic development and employment in the County and in doing so supporting many communities. This is reflected in the geographic footprint the company occupies within the County which extends to approximately 5,597 hectares.

As a global community, we are faced with the challenge posed by climate change and as a society we have acknowledged the need to meet this challenge. In keeping with this, Bord na Móna is committed to decarbonising its business and while we have embarked on this journey some time now, the pace of this transition has increased in recent years and continues to increase at pace. The impact this transition is having on the communities which we support, and the wider economy and social fabric of Westmeath is not lost on us. As we continue this challenging journey we are committed to repurposing and applying our assets, not least our land assets, to support and develop the future economy of Westmeath.

However, with these challenges come opportunities, some which we have identified such as in the area of renewable energy, more which are in development such as aquaculture and more still which we have yet to even identify. In finalising the County Development Plan, it is important that we not close the door to the range of future commercial and job creation opportunities which may be supported by Bord na Móna’s land and property assets within the county.

In this context, it is important to reflect on the nature and uniqueness of this significant landholding. While somewhat fragmented in geographical spread, much of the company’s estate is characterised by large tracts of land. This is a somewhat uncharacteristic feature in the context of Irish landholding and therefore offers unique opportunities for a multitude of uses not readily suited to smaller dispersed landholdings. This, coupled with proximity to the national electricity infrastructure and relative isolation from residential areas, is particularly suited to the development of renewable energy such as windfarms and solar farms and other large-scale industrial development. Most of our peatland has been utilised for industrial peat extraction for decades and consequently much of the overlying peat deposits has been cutaway. This peat extraction activity has been undertaken under licence (Integrated Pollution Control Licence) from the Environmental Protection Agency. Under the terms of this licence, as we exit peat extraction activities, this cutaway will be environmentally stabilised through the implementation of a rehabilitation programme with significant portions of these lands rewilding and supporting biodiversity and other ecosystem services. We believe that it is possible to successfully integrate this emerging biodiverse and amenity rich landscape with other commercial, industrial and employment generating uses.

This is exemplified in the transformation of our Mountlucas property in county Offaly which has changed from a site with a single use (peat harvesting) to one hosting a rich mosaic of complimentary activities. Over the last decade an 84MW windfarm has been developed on the site. The windfarm supplies over 50,000 homes with renewable electricity while providing a sustainable income which in turn supports significant local community investment. With the wind assets occupying a mere 5% of the 1,100-hectare site, this rehabilitated cutaway has helped significantly mitigate carbon emissions and also developed into a rich ecosystem with a range of different habitats for native plants and animal species. The site also provides a new significant public amenity with over 20km of walking/running/cycling tracks for people living in the local communities. In addition, the company has also developed a number of new business projects on the site including a closed loop re-circulation aquaculture facility and the cultivation of high value herbs used in the production of alternative medicines and food supplements.

In 2011 Bord na Móna published its long-term land use strategy, Strategic Framework for the Future use of Peatlands. Much of the strategy outlined in this framework document still holds true and is relevant; however, with the significant and accelerated change that has taken place in the intervening period and with the emergence and identification of new potential future land uses, we have engaged in a review of this framework. As outlined later at Chapter 12.17 we expect to publish a revision of the Strategic Framework in the coming weeks and it will be made available to stakeholders.

The Draft Westmeath County Development Plan invites submissions across a broad range of important topics and we believe Bord na Móna can make significant positive contribution across many of these areas. In particular, we believe we have a significant role to play in delivering on climate action and energy policy, supporting natural heritage and biodiversity, growing tourism, fostering the establishment of new, sustainable industrial and commercial development and supporting rural and urban regeneration.

This submission will now provide commentary on specific sections of the proposed Draft Plan in addition to information on how Bord na Móna is working to support and endorse National, Regional and Local policy, objectives and targets in relevant areas and so as to inform the development of this draft and adoption of a final plan.

Observations

Submission from Bord na Mona Part 1 re: Suggested amendments in reference to 10.22 Renewable Energy Sources

10.22 Renewable Energy Sources

Include additional bullet point,  under the bullet point “The Government’s National Mitigation Plan, July 2017 (DCCAE).’ To read:

The Government’s National Energy and Climate Plan as submitted to the EU Commission under the Regulation on the Governance of the Energy Union and Climate Action (EU/2018/1999)

Submission from Bord na Mona Part 2 re: Suggested amendments in reference to 10.23.2 Industrial Scale Wind Farms

10.23.2 – Industrial Scale Wind Farms Pg.308

First paragraph, 2nd last sentence – replace ‘worked-out’ with ‘former’ industrial peatlands

 

Same Section: Wind Policy Objectives CPO 10.135

Removal of final bullet ‘carbon emission balance’ – Increase in overall carbon losses is a matter to be considered and is relevatn for all land types regardless of soil type. 

Submission from Bord na Mona Part 3 re:10.26 Bio-energy & 10.27 Hydro

It should be noted that these types of biomass products can be combusted in any boiler and for clarity we would suggest to amend to the following wording in paragraph 2 (Pg. 312)  including the recommendation to amend CPO 10.146.

10.26 Bio-Energy

The 2nd sentence in paragraph 2 is not factually correct.

  • “All dry resources; wood and wood residues (forest or sawmill residues) and dry agricultural residues such as straw, can be combusted to produce heat, electricity or both, and can also be co-fired in existing solid fuel systems.”

Replace with

  •  “All dry resources; wood and wood residues (forest or sawmill residues) and dry agricultural residues such as straw, has the potential to be combusted to produce heat, electricity or both, in suitable designed boilers.  However, it must be noted that for typical commercial and industrial biomass burners as well as domestic units, a high specification biomass fuel must be used. Forest and wood residues requires larger more robust boiler units – typically those used to generate electricity from peat.”

10.27 Hydro

 Recommend the inclusion of an additional CPO after CPO 10.146

"Support the development of an indigenous bioenergy sector, including the mobilisation of low value residual biomass for the production of renewable electricity."

 

Submission from Bord na Mona Part 4 re: Chapter 10 – Section 10.23 Wind Energy

Chapter 10 – Section 10.23 Wind Energy

The National Climate Action Plan (CAP) 2019 has set out an ambitious 70% target for renewable energy production out to 2030. To meet this target, the amount of electricity generated from renewables will have to be doubled on current figures. It is our view that the proposed Westmeath CDP must plan for and be supportive of all forms of renewable energy generation in order to contribute to this target and to Ireland’s transition to a competitive low carbon, economy by 2050.

Given the unique nature, character and scale of Bord na Móna's cutaway bogs we believe that the future use of these lands has the potential to make a significant contribution to national policies and objectives across a range of sectors including renewable energy, industrial development and job creation in rural areas, ecosystem services and biodiversity as well as tourism, amenity and recreation. In many cases these uses can be co-located thereby providing enhanced economic benefits to the areas in which such developments are located through direct and indirect employment opportunities. The optimisation and the realisation of the full potential value of the company's land bank is dependent on national, regional and local planning.

The suitability of peatlands for renewable energy developments in particular wind energy has been highlighted in the National Planning Framework (Project Ireland 2040) and in the Regional Spatial and Economic Strategy for the Eastern and Midland Region. In this regard, Bord na Móna warmly welcomes the inclusion of the following text in Section 10.23.2 of the Draft Plan on Industrial Scale Wind Farms:

“The Regional Economic and Spatial Strategy for the Eastern and Midland Region (RSES) refers specifically to the after use of peatlands and consideration of their potential contribution to climate change mitigation and adaptation including renewable energy production. With a strong history of energy production and an extensive electricity transmission network in place, the potential exists in such peatland areas for a smooth transition to renewable energy sources……The preferred locations for large scale energy production, in the form of windfarms, is onto cutover cutaway peatlands in the County, subject to nature conservation and habitat protection requirements being fully addressed.”

In addition, Bord na Móna welcomes, the many specific policy objectives listed in Section 10.23.2 addressing renewable energy, in particular the following:

CPO 10.135: Encourage large-scale energy production projects, in the form of Wind Farms, onto cutover cutaway peatlands in the County, subject to environmental, landscape, habitats and wildlife protection requirements being addressed.

These policy objectives point toward the significant potential for renewable energy development in County Westmeath. However, the inclusion of policy objective CPO 10.132, which specifies separation distances between wind turbines and residential dwellings is of significant concern, as it essentially prohibits the development of wind energy projects on Bord na Móna lands in the County and is in direct conflict with national and regional policy objectives to support the development of wind energy on peatlands and contribute to Ireland reaching its 2030 targets. It is also in conflict with the Wind Energy Development Guidelines 2006 and the Draft Revised Wind Energy Development Guidelines 2019 which state the following with respect to setback in Section 6.18.1:

“Taking account of the various factors outlined a setback distance for visual amenity purposes of 4 times the tip height should apply between a wind turbine and the nearest point of the curtilage of any residential property in the vicinity of the proposed development, subject to a mandatory minimum setback of 500 metres.”

 

The Guidelines go on to state that:

 

“It is a specific planning policy requirement of these Guidelines under Section 28(1C) of the Planning and Development Act 2000, as amended, that, in both their development planning and management functions, planning authorities shall not apply a setback distance that exceeds these requirements.”

Bord na Móna believe Westmeath County Council need to review and amend CPO 10.132 in light of this; not only to ensure consistency with the Guidelines, but also to ensure the Council’s wider commitment to support and enable renewable energy generation can be achieved.

 

Map 48: Wind Capacity

Bord na Móna also welcomes the commitment in Policy Objective CPO 10.149 to prepare a Renewable Energy Strategy for the County. In this regard, we would urge the Council to carry out a full assessment of renewable energy development in compliance with the methodologies outlined in SEAI Methodology for Local Authority Renewable Energy Strategies (LARES) and with the current Wind Energy Development Guidelines (2006) and the Draft Revised Guidelines (2019). This will ensure that a consistent and transparent renewable energy zoning methodology is in place for all developers.

On a similar note, we also request that in parallel with the development of a Renewable Energy Strategy, that the Council reviews the Landscape Character Assessment for the County to ensure a consistent approach to the determination of lands that are suitable for the development of wind energy projects in the County. Currently, as an example, the Bord na Móna Ballivor Bog Group (Westmeath portion) sits within the River Deel Lowlands landscape character area. While peatlands have been identified as being suitable for wind energy development, the River Deel Lowlands are designated as being of “Low” suitability for Wind Energy in Map 48: Wind Capacity, which is a contradictory situation. It is our view, that a review of the Landscape Character Assessment for Co. Westmeath in conjunction with the development of the Renewable Energy Strategy will result in greater clarity regarding the suitability of lands for wind energy development and will assist developers eliminate uncertainty at project inception stage.

 

 

Submission from Bord na Mona Part 5 re: Accelerated decarbonisation programme

Bord na Móna is now developing an accelerated decarbonisation programme.  The company has also committed to a significantly larger rehabilitation target. This is reflected in our plans to rehabilitate a further 20,000 hectares of cutaway and cutover bog to wetland and woodland mosaics by 2025. In addition, we plan to restore a further 1,000 hectares of raised bog habitat by 2025 for example at Mostrim Bog (currently underway) and Glenlough Bog (proposed) in Co.Westmeath. These targets are significant in both timing and scale and are indicative of Bord na Móna’s increased new ambition in this area.  This will deliver significant climate action and ecosystem service benefits.  The development of naturally functioning peatland ecosystems will lead in time to the restoration of carbon sequestration potential. This will support the main carbon mitigation land-use objectives of the National Climate Action Plan, as reflected in the Westmeath County Development Plan, while also providing other benefits for biodiversity and other ecosystem services. 

As can be seen from our Strategic Framework for the Future use of Peatlands, Climate Action is considered very important to the organisation and Bord na Móna can achieve these objectives in harmony on our cutaway and cutover peatlands with other commercial, industrial and employment generating land uses such as renewable energy, tourism and recreation.

Submission from Bord na Mona Part 6 re: 12.17 Peatlands

Of the 17,000 ha of peatland in County Westmeath Bord na Móna own approximately one third; with much of this landholding connecting to larger peatland areas in neighboring counties. Much of our estate in Co. Westmeath comprises a mix of “cut-over” and “cut-away” bog which, with the accelerated cessation of peat extraction, present significant opportunities to achieve climate action and biodiversity objectives through appropriate rehabilitation and where possible restoration in conjunction with other commercial activities for example, the proposed Ballivor Wind Farm. Indeed, we have already restored several raised bog areas in County Westmeath and we are currently developing plans to accelerate and enhance our rehabilitation programme for the remaining areas using best practice restoration and rehabilitation methodology. This rehabilitation programme will support the main carbon mitigation land use objectives of the National Climate Action Plan while also providing other benefits for biodiversity and other ecosystem services.

Furthermore, we believe and indeed have demonstrated at our site in Mountlucas, Co Offaly, that it is possible to deliver on climate action and biodiversity objectives through peatland rehabilitation in perfect harmony with achieving other policy objectives and leveraging commercial opportunities, in particular, renewable energy generation and supporting indigenous, compatible new commercial opportunities. The former industrial peatlands at Mountlucas, for example, now supports an 84MW commercial wind farm surrounded by 1,100ha of rehabilitated peatland which has transformed this industrial landscape into a diverse mosaic of ecosystems from wetland to heathland to woodland. Mountlucas is also the site of the Company’s trial inshore aquaculture facility, the first of its kind, and also supports our emerging herb cultivation business.

With respect to CPO 12.58, “Exercise control of peat extraction, both individually and cumulatively, which would have significant impacts on the environment”, we would like to point out that all Bord na Móna’s historic peat extraction activities have been carried out under Integrated Pollution Control licences issued and monitored by the Environmental Protection Agency. As we transition from peat extraction and commence rehabilitation, we remain under the control of these licences which require us to stabilise the cut-over and cut-away peatlands through decommissioning and rehabilitation measures agreed with the Agency. In light of this we believe that CPO 12.58 ought to be amended to include the following text after “…control of peat extraction…”:

“…activities not otherwise controlled by the Environmental Protection Agency or pursuant to an environmental licence,…”

 

We welcome the principle of a regional approach to the planning for the future of the post-industrial peatlands across the Midlands as called out in CPO 12.60. As custodians of the country’s industrial peatlands we have over 30 years’ experience in the rehabilitation and, where possible, the restoration of these landscapes. We have also identified appropriate alternative sustainable future uses which we have successfully integrated with this rehabilitation process as demonstrated at Mountlucas, Lough Boora and Oweninny for example. In 2011 the company published its “Strategic Framework for the Future Use of Peatlands” identifying the challenges and opportunities associated with the re-purposing of industrial peatlands; and outlining the factors which should be considered in developing a future use strategy for these peatlands. With the accelerated decarbonisation of our business operations in recent years and especially in the last 12 months we have reviewed and updated this framework with the revised edition due to be published in the coming weeks: Bealach Úr, Bealach Glas - The Future use of our Peatlands.  We believe that this plan should be acknowledged and specifically called out in CPO 12.60. CPO 12.61 in calling for a collaborative approach in the development of an integrated peatland management plan echoes similar objectives at CPO 10.138 and CPO 11.6. We consider future sustainable peatland management inherently linked with the future land use strategy. We believe and indeed we have demonstrated at Mount Lucas, Oweninny and Lough Boora that our peatlands can be re-purposed to harmoniously deliver in the areas of renewable energy, recreation and amenity, climate mitigation and biodiversity. In the context of developing such a peatland management plan we suggest that our strategic plan, “The Future use of our Peatlands” should inform its development.

For the avoidance of potential inconsistencies, we suggest that only one of the three CPO’s referred to in the previous paragraph should be retained in the final plan or if they are each to remain, they ought to be drafted in identical terms. Similarly, we suggest that the objectives of CPO 12.63 is encapsulated in CPO 12.61 and ought therefore to be removed from the final plan to avoid potential ambiguity.

Information

Unique Reference Number: 
WM-C1-87
Status: 
Submitted
No. of documents attached: 
1
Boundaries Captured on Map: 
No