submission no. 4 to whom it may concern...1 submission no. 4 to whom it may concern: i would like to...

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Submission No. 4

To whom it may concern:

I would like to register my objection to the proposed off shore wind farm in Dublin bay. I consider

the horrific proposal to be a detrimental blot on the landscape with unknown impact on marine life

and birds in one of south county Dublin’s greatest amenities and tourist attractions. I believe this

huge and unnecessary wind farm would have a serious negative effect on our tourism industry and

to our natural local heritage. I am deeply concerned that such a proposal could even be considered

so close to the shore and so wide and so tall as to completely ruin the view of the bay as it exists

now. I am also aghast that such a thing could be considered when there is absolutely no guarantee

of any positive outcome to the local residents at all - not monetary, not fuel, not Irish jobs,no amebic

enhancement - just another gigantic mistake which would change the landscape and feel of our

waters forever.

Kind regards

Submission No. 12

To whom it may concern

Please take this as my formal objection to the proposed wind farm located off shore from Bray Head.

This project is insensitive to the environment and has proceeded without proper consultation

Regards,

Submission No. 13

I wish to object to the proposed Dublin Array. I believe that the massive extent of the proposed

Wind Generators would seriously detract from the great amenity that is Dublin Bay and the Irish Sea,

that together provide an unspoilt backdrop to Dublin City.

I support the idea of alternative energy and the role of Wind Generators in areas remote from

habitations. If there is a decision to give some support to the present proposal then I suggest that a

trial installation of a small group of Generators only be considered such as those already offshore

near Arklow.

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Submission No. 18

Dear Minister

Everyone agrees that we need to ensure that Ireland's energy needs for the future will come from a

mixture of renewable resources, of which wind is but one, and that we have to reach our

Kyoto targets. However it is also important that any renewable energy project approved does not

come at too high a price. I am concerned about having 145 turbines on the Kish & Bray banks, with

the nearest turbine a mere 9.7km off Coliemore Harbour & all 145 turbines visible from 15

viewpoints around the Bay including the Vico Road and Howth Harbour, according to Saorgus's own

photomontages.

We must ensure one of our most beautiful bays, right beside our capital city and home to all manner

of wonderful wildlife, is safeguarded. Dublin Bay is a stunning natural asset - it would be so wrong

to industrialise it. It provides such a magnificent backdrop, attracts tourists & facilitates so many

leisure pursuits - swimming, walking, canoeing, boarding, sailing, fishing, rowing, painting,

birdwatching (important colony of roseate terns on Rockabill). It is a training ground for young

people in marine leisure sports and marine biology with its porpoises dolphins & seals. It has seen

so much history, is so much a part of the nation's heritage and environmental wealth. We are so

privileged to have it, why risk destroying it for future generations ? Why risk destroying any aspect

of it ? Who knows if after the construction phase wildlife will return, if seabirds will return, if

currents & depositions will be negatively affected ? Every site is unique and previous experience will

not necessarily apply. Who knows if wind will sometimes carry noise from turbines into residential

areas & drive people mad ? Research done for promoters can be insufficient, can be biased, can be

too little too late, can be plain wrong. Of course the promoters' presentation says all possible

impacts are low. What else would they say ? Once installed, turbines will not be removed even if it

becomes clear that a mistake has been made. We will be stuck with them and whatever

their consequences may be.

Naturally the developers want to locate the project on a shallow sandbank as installation & running

costs will be cheaper & more profit will accrue to them. However it is a fact that many wind farms

are already operating 22km or more from shore in other countries & although in deeper water, they

are still making enough profit. We can be justly proud that Ireland has boxed above its weight in

so many important initiatives, from smokeless coal to taxing plastic bags, the smoking ban, & now

plain pack cigarettes. Let us continue best practice set by other countries by making it a condition

of granting leases that all installations must be min 22km from our shores. I have no doubt that

exploration companies will factor in the extra cost and still be keen to proceed.

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It is vital also that a proper tax take is a condition of granting any lease, given that assets belonging

to the people of Ireland have in the past been inexplicably & irresponsibly surrendered by the

government for little or no return.

Finally, I understand that the government have approved the installation of a massive number of

turbines in the midlands area for the purpose of supplying the UK to help them meet their Kyoto

targets. It appears from media reports that this is because the UK wouldn't tolerate this happening

in their own countryside ! I also note that the primary market at which the Dublin Array is aimed is

also the UK and of course on into the wider markets of Europe .

The inescapable conclusion of all this is that we are being taken for complete fools. How dare the

government agree to this ? Can it be true that we should allow our quality of life, environment,

wildlife, landscapes & seascapes be degraded so our nearest neighbours can preserve theirs !! If

this insanity is allowed happen, everyone in the UK, not just Tesco managers, will have good reason

to refer to Ireland not only as Treasure Island but as Gullible Greedy Gobshite Paddy Island !

Please let right reason prevail even at this late stage. Let us take a step back here & have the

intelligence to approve windfarms only subject to the strictest criteria, and as only one element of a

wider renewable energy strategy. Ireland has an unparalleled advantage in the world as a beautiful

green island, temperate climate, beautiful landscapes & seascapes, wholesome food. Don't make it

into Europe's offshore turbine installation. Don't throw it all away. Please.

Yours sincerely

Submission No. 19

Dear Sirs,

I wish to object to the above application, and fully support the submission made by the Coastal

Concern Alliance concerning same.

The quantity , size, and number of these turbines would serious damage the visual amenity of

Dublin bay and its surrounds.

Regards,

Submission No. 20

To whom it concerns,

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I wish to object to this plan as the perfect views and much loved natural skyline draws so much

tourism to our area.

Wind farms should be placed farther out at sea so as to not be visible from the coast.

Hopeful that you will listen to reasonable objections,

Yours kindly,

Submission No. 30

Extended Public Consultation period for Dublin Array wind farm lease application

I have very serious reservations about the environmental impact of the proposed wind farm in

greater Dublin Bay area. The proposed wind turbines will be an eyesore to blot the view from Howth

in the north to Bray in the south and possibly further afield. There is also potential noise pollution

and the damage to sea life in the vicinity.

Given the high level of public concern about this proposal I hereby call on the relevant Minister to

initiate a public enquiry into the proposal before any licence is granted.

Regards

Cllr. Jim O’Dea

Submission No. 31

Having seen the plans and photomontages of this wind farm proposal, I am quite shocked at the

possibility that this might come to pass.

My objections relate to the following:

1) the effect on the landscape along this area which is renowned for its natural beauty and is of great

importance to our tourism industry;

2) the harmful effects on protected habitats such as shallow sandbanks and marine mammals;

3) its non-compliance with EU environmental legislation and,

4) the huge number of turbines proposed.

The photographs (seen in Dun Laoghaire Library) with these proposed turbines are disturbing as the

viewpoints are slightly misleading - lower viewpoints would indicate just what the visual effect of

this would be for those living, visiting and sightseeing along this coast.

The impact of such a proposal would have far-reaching and quite detrimental effects on our

beautiful coastline and landscape. It would be shameful if the Department of the Environment

allows it.

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Submission No. 33

Dear Sir/ Madam,

I wish to make a submission on behalf of my local community in relation to the Dublin Array

application for construction of an offshore wind farm.

I am strongly in favour of offshore wind farms in appropriate places and the development of wind

and renewable energy.

However I also think that the economic and environmental benefits of developing wind energy must

be carefully balanced with respect to the economic benefits that accrue to Dublin from tourism and

the impact that this wind farm will have on views from areas such as Howth which enjoy large

numbers of tourists at present.

Of course calculating the economic cost of impacting on the view of Dublin Bay from Howth and

other locations is very difficult. However I think it is reasonable to conclude that while a wind farm

will have little negative impacts for many tourists and visitors to Howth, for others it will spoil what

is one of the most spectacular and beautiful views on the East Coast of Ireland.

I would ask that this is strongly considered during this application and that permission for a licence

this project is refused.

Sincerely,

Cllr. Cian O'Callaghan

Submission No. 34

Having seen the proposed sites for the wind turbines I can only say that I am extremely shocked to

think that anyone could even think of spoiling such natural beauty for future generations. Please

take note of my objection

Submission No. 37

I have a positive disposition to renewable energy and to Wind generated power but there has to be

care taken in the location and scale of Wind Farm Developments.

The development of 145 Wind turbines will be one of the largest such marine based developments

in Europe.

The development is far too close to the shore, contrary to international best practice and the scale

of the development will have a very major visual impact.

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The proposal is in contravention of the Dun Laoghaire Rathdown Development Plan.

It will be in conflict with Objective Map 4 Proposed Natural Heritage Area for Dalkey Island, the

Muglins and surrounding area.

A detailed tender procedure must be set out.

440 turbines have been approved with 200 more at Coddling and then 145 at Dublin Array. This is

not acceptable.

Submission No. 38

C/o Mount Salus House

Mount Salus

Dalkey

23th June 2013

Department of the Environment, Community and Local Government,

Marine Planning and Foreshore,

Newtown Road,

Wexford, Co. Wexford

Submission by Dalkey Community Council

in response to application for Foreshore Lease for Dublin Array Wind Farm

Reference number MS53/55/L1

Dalkey Community Council has concerns about the application for a Foreshore licence for

the proposed wind farm at the Kish and Bray Banks in particular the very large number of

turbines (145) to be installed within 10km of the coast line with the attendant

environmental issues. We are fully supportive of the submissions of Coastal Concern

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Alliance and the Irish Whale and Dolphin Group who have described in detail these issues in

addition to our concerns with the E.I.A.

We note that the E.I.A of such a project should be based on the precautionary principle-

(ENVIRONMENTAL IMPACT ASSESSMENT DIRECTIVE 2011/92/EU OF THE EUROPEAN PARLIAMENT –

Para 2). It would appear that this is not the case with the developer’s statement.

As a local community group actively involved in local issues, we were not informed of the

proposed application which will have an impact on our immediate environment;

Article 1(c) of the above directive states

“‘public concerned’ means the public affected or likely to be affected by, or having an

interest in, the environmental decision-making procedures referred to in Article 2(2). Also

Article 2(b) states” make available to the public concerned the information obtained under

other forms of assessment referred to in point (a), the information relating to the decision

granting exemption and the reasons for granting it;”

We therefore believe that this application does not comply with EU law.

We believe that the developer’s EIS is inadequate in that it does not describe or assess the

project’s effect on the landscape/seascape, its human impact or its effect on the material

assets of the adjacent population as is required by the above EU Directive of the European

Parliament-Article 3 states-

“The environmental impact assessment shall identify, describe and assess in an appropriate

manner, in the light of each individual case and in accordance with Articles 4 to 12, the direct

and indirect effects of a project on the following factors:

(a) human beings, fauna and flora;

(b) soil, water, air, climate and the landscape;

(c) material assets and the cultural heritage;

(d) the interaction between the factors referred to in points (a),

(b) and (c).

There is no reference to the effect of this large–scale development on the material assets of

any locality and therefore does not comply with EU legislation.

Article 5 of the Directive states that amongst other information provided by the developer

in their EIS they should include at least

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5c) the data required to identify and assess the main effects which the project is likely to

have on the environment;

5d) an outline of the main alternatives studied by the developer and an indication of the

main reasons for his choice, taking into account the environmental effect

We have studied the EIS and find that the information provided is neither appropriate nor

accurate and that the images provided are inaccurate and provide a false impression of the

impact of this huge development. We note that the Irish Whale and Dolphin Group state

that the information in the EIS is inaccurate and misrepresentative in regard to the effect on

cetaceans. Again, the EIS does not fulfil EU legislation.

We have concerns that the public along the East coast and the Dublin area, as well as more

locally in the Dalkey area, are not aware of this large scale proposal and the effects it will

have on their environment. We were not informed of this application for a marine

development, as the process by which the public are informed is totally inadequate, unlike

land based development; (we publish all developments relating to Dalkey in our monthly

newsletter). There is virtually no public awareness of the application, the EIS or the public

consultation process.

Note Article 6.2 of Directive 2011/92/EU of the European Parliament –

“The public shall be informed, whether by public notices or by other appropriate means such

as electronic media where available, of the following matters early in the environmental

decision-making procedures referred to in Article 2(2) and, at the latest, as soon as

information can reasonably be provided”

Article 9 states “When a decision to grant or refuse development consent has been taken,

the competent authority or authorities shall inform the public thereof in accordance with the

appropriate procedures and shall make available to the public the following information:

(a) the content of the decision and any conditions attached thereto;

(b) having examined the concerns and opinions expressed by the public concerned, the main

reasons and considerations on which the decision is based, including information about the

public participation process;”

We look forward to the Minister’s decision and the main reasons and considerations for it,

in light of the information available and the public‘s submissions.

The developer’s EIS states that the 145 turbines will be in excess of 10km from the nearest

house but describes them to be 9.6km in another part of the submission; the reality is that

this wind farm would be the closer to the shore than anywhere else in the world. A

minimum separation distance of 500m will be provided between the turbines in both

directions. The resulting wind farm will stretch for 18km and be 3km wide. Two metrological

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masts are also described but do not appear in any of their photomontages. The developer

has indicated in his EIS that there will be “significant” visual impact from including Howth,

Clontarf, Sutton, Bull Island, Poolbeg/Ringsend, Sandymount, Dalkey, Killiney, Bray,

Greystones, Newcastle, Sugar loaf Mountain, the N11 at Kilmullin, Carrickgollogan Hill,

Shankill and Wicklow Town.

“Adverse Major” visual impacts are predicted by the developer for Bray Head, Killiney Hill,

Vico Rd and Howth Head all nationally scenic areas. These effects listed in the E.I.S. give

some idea of the immense visual impact the Dublin Array wind farm would have on the

entire coast from Howth to South Wicklow.

The visual impact of this huge wind farm in addition to the 220 turbines already permitted

on the Codling Bank and a further 220 proposed in the same place and the 55 already well

advanced in Dundalk Bay will result in the industrialisation of the East Coast. It should also

be noted that the current seven existing turbines on the Arklow bank are less than 100m

high. This compares with 160m for the Dublin Array proposed turbines. The visual impact

will be enormous in addition to wide scale environmental disturbance and destruction of

habitats which has not been acknowledged by the developers.

We are surprised that in the Draft Offshore Renewable Energy Plan (DOREP) and in the

developers E.I.S. reference is made that these proposed wind farms are considered “existing

renewable infrastructure” before even a foreshore licence has been granted or the public

consultation has been completed; it is indisputable that these structures are not there, they

do not exist.

We note that the Heritage Council of Ireland in their submission in relation to the DOREP

are concerned about this anomaly.

In summary we have widespread concerns in relation to

1) non-compliance with EU law,

2) the environmental issues identified in the EIS,

3) the adverse major visual impacts on nationally important landscapes/seascapes

4) draft national legislation in relation to the marine planning process still incomplete

In view of our concerns, we believe a foreshore lease should not be granted for this

development.

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Submission No. 39

I would like to mention that I have many issues with you putting up the wind banks.

1. The will ruin the natural beauty of our coastly area.

2. They would be a knewsence to boats and other small water crafts.

3. It might ruin the natural habitat of the fish, crabs, sharks and etc.

These are all my issues I hope you read this and see all points and see what damage it could do to

our Country.

Submission No. 41

Dear Sir or Madam,

We would like to object in the strongest possible terms to the proposal to build a windfarm on the

Kish and Bray banks in Dublin Bay, on the grounds that they would constitute an intrusion on the

visual aspect of the bay.

Dublin Bay is an area of great scenic beauty upon which the construction of up to 145 wind turbines,

as reported in the Evening Herald (18 April 2013), would have a devastating impact. As well as

spoiling the view of the bay from land and sea perspectives for Irish citizens, such a development

would also undermine efforts not only to promote Ireland, but specifically Dublin city and bay and

Wicklow, as tourist destinations renowned for their natural beauty and scenic attractions.

We therefore believe that locating the windfarm at such a central site in Dublin Bay, in addition to

its detrimental effect on the beauty of the bay, will also have a negative economic impact.

We would urge those responsible to visit the North Wales coast and see how an attractive stretch of

the coastline near Rhyl, visible from the railway line and coastal road, has been compromised by the

construction of wind turbines which have the effect of closing down the view out to sea and create a

prison-like appearance.

Is this what we want for Dublin Bay? A gated entrance to the Garden of Wicklow?

Yours sincerely

Submission No. 45

The Department of the Environment, Community and Local Government

Marine Planning and Foreshore

Newtown Road

Wexford

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Co. Wexford

26.06.2013

Dear Sirs,

Re: application for foreshore leases, reference no. MS53/55L1, in respect of the Windfarm

Development referred to as The Dublin Array.

I make this submission as a result of the many representations I have received on this matter from

concerned constituents with which I concur.

In Dún Laoghaire Rathdown the local economy relies heavily on visitors to our county, and this is a

sector we are currently trying to build, since ours is an area of outstanding beauty. Visitors come

because of our heritage, our architecture and our stunning coastline. The visual amenity of our

county is of central importance to our economy, but also to our identity and the pleasure and

satisfaction we all take in the area we live in. The sea is a part of everyone who lives here.

The visual and environmental amenity of Ireland over the past 30 years was substantially

disimproved though a dearth of planning controls which resulted in widespread haphazard and

unattractive low-density development which has been especially detrimental in areas of exceptional

beauty. Thankfully we have learned our lesson about this and we have evolved a subtle and far

reaching web of planning regulation which delineates the criteria against which any new

development must be judged. We now regulate development on land, but not yet at sea, although

the sea is also part of our environment, and a very important part for a coastal county like Dun

Laoghaire Rathdown. The sea is not only visible from almost every part of the county, but forms a

substantial part of our physical environment.

No doubt there will always be a certain reluctance to welcome structures as enormous and intrusive

as wind turbines, wherever they seek to find a home, however worthy a project renewable energy is

- and it is. But to place up to 145 wind turbines, a virtual forest of them, taking up the entire visual

field of Dublin Bay, where 1.8 million of the population of Ireland live (i.e. 40%) – this is visual

vandalism.

I do not believe this is an appropriate development for Dublin Bay, but on the contrary would be a

desecration of it, and for what? I understand that Ireland is well on course to meet our 2009 EU

Renewables Directive target of 16%. There are alternative sites for such a development. Let us not

sell our visual heritage in this way, but protect it for ourselves and for future generations.

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Patricia Stewart

Fine Gael County Councillor for Dún Laoghaire

Submission No. 46

To the Department of the Environment, Community & Local Government.

Dear Sirs,

We have carefully read the Environmental Impact Statement submitted by the applicant and have

noted the photo montages annexed thereto.

We are deeply shocked at the size and scale of the proposed development.

We also note with dismay that Foreshore Leases have already been granted for large scale wind

farms on the Arklow Bank and the Codling Bank.

The Dublin Array proposal is 17km long. Combined with the Codling Bank wind farm it would

comprise a continuous line of turbines 35km long.

We have carefully read the submission of Coastal Concern Alliance made to the Department. We

wholly endorse and repeat the points made by Coastal Concern Alliance in their submission to you.

We are deeply concerned at the short and long term impact the proposal by Dublin Array will have

on the environment. Having seen the adverse affect the current small number of turbines on the

Arklow Bank have when viewed either from the sea or the land, the prospect of 145 turbines sited

10km from the Co Dublin and Wicklow coast is mind boggling.

The views from Howth to Bray head will be forever destroyed, the land/seascape will be

industrialised ,the protected sandbanks degraded and the proposal will have serious consequences

for the wellbeing of marine wildlife and birds. It will also have a severe impact on navigation, fishing

and sailing. What any future tourist would think when seeing a wall of turbines so near such a

beautiful coast can only be imagined.

We object to the granting of the Foreshore Lease on the grounds set out by Coastal Concern Alliance

and as set out by us above.

Kindly acknowledge receipt.

Yours sincerely

Submission No. 49A

I object strenuously to this proposal to build wind turbines in Dublin bay and its environs.

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Submission No. 49B

I am a private individual writing to support the submission from Dublin Bay Concern on the proposed

Dublin Array wind farm project on the Kish Bank (MS53/55/L1)

SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT

RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1)

Submission No. 54

Dear Sirs,

I wish to object to the planning for the wind farm under the above reference.

Yours faithfully

Submission No. 55

I am making a submission on the proposed Wind Farm project and strongly object to this project on

the following grounds:

The size and scale of the proposed project

The negative visual impact of it

The negative environmental impact on the Dublin/Wicklow coast.

Submission No. 56

I oppose the plan for the Wind farm as:

The size and scale of the project will negatively impact on a coastal area that is beyond doubt one of

the most scenic areas in Ireland

The impact on the wildlife from the Dublin to Wicklow coasts will be immense

Where will the power be brought ashore?

The profit from this venture will NOT benefit Ireland

Submission No. 57

I make the following objections to the proposed Wind Farm

The number of turbines planned is far too numerous

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The height of the turbines is too excessive

Their proximity to the shore must not be permitted

The most scenic coastline in Ireland will be totally destroyed

There will be no economic benefit either to the national or local economies

There will be a detrimental effect on the wildlife.

Submission No. 58

Dept of Environment, Community & Local Government

Marine Planning and Foreshore

Newtown Road

Wexford

Co. Wexford.

Re: Lease Application Ref MS53/55/L1.

To whom it may concern,

I wish to object to the granting of the above lease.

I am Japanese and have lived in Ireland for most of my life. I love this country and the unspoilt

beauty of it. I work as a tour guide helping tourists from Japan to appreciate it too.

In Japan there is huge resistance to the development of wind farms. The people do not like the way

they destroy the natural environment. I believe it would discourage Japanese tourists from coming

to Ireland. Tourism is a huge industry here and we should preserve the beautiful natural scenery so

that it remains so.

Please do not grant this lease.

Submission No. 59

I am a private individual writing to support the submission from Dublin Bay Concern on the

proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1)



Background:

Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding

Dublin’s foreshore and ensuring that any development within the bay protects and preserves our

natural and cultural heritage.

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The group was formed in the wake of the application for a foreshore licence made in January 2012

by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory

well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence,

Providence Resources Ltd surrendered the licence following a legal challenge concerning the

application of the environmental impact assessment directives to the project. The Kish Bank licence

application typified the problems inherent in the existing system for the regulation of development

of the foreshore: inadequate opportunity for public consultation and engagement, insufficient

regard for environmental issues and uncertainty for investors.

Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of

economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an

abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay

Concern contend that the Bay is an amenity for all and that care and due process must prevail when

considering development of the foreshore.

Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%.

These are compelling statistics and show how important a resource Dublin Bay is, a resource that is

worthy of our protection and conservation.

Special Area of Conservation:

Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000

hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish

Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined

particular common concerns which also related to this submission:

The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict

protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the

IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the

highest recorded anywhere in Ireland.

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In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU

habitats directive.

Dublin Array Application for Foreshore lease:

We are all in favour of green energy methods but these too must follow an ethos of environmental

protection which requires proper and extensive environmental impact studies to be carried out.

It is our view and the view of other groups, including The European Platform against Windfarms

Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has

not been done adequately in the case of the Dublin Array proposal.

An extract from the EIS provided by Saorgus as part of their application states:

‘More knowledge and experience are needed before definite conclusions on impacts can be drawn

“Whilst research is ongoing on certain impacts, e.g. underwater noise, electro-magnetic fields, bird

displacement, public perception, there are also several aspects of offshore wind-farm developments

where the effects are fully understood (e.g. suspended sediment concentrations from monopile

foundations installation and cable laying; scour pit development around monopiles; seabed

morphological effects within arrays of monopile foundations and species composition and rates of

organisms colonising the sub-sea structures). Only a relatively small number of developments are

operational so the determination of definitive trends is not possible. "

An international website has been set up by OSPAR to pool information and data on environmental

impacts associated with this industry (www.environmentalexchange.info) companies. This site is a

voluntary site for wind energy companies who are interested in the effects of turbines on the

environment. The contents of the website are not encouraging. It is not easy to find out about the

effect or recent studies on effects of wind turbines on the environment. It is obvious from this that

these companies need help and guidance and rules in order to care for and be interested in the

effects of their developments.

We would recommend that existing offshore wind farms introduce a system of data collection with

regard to birds and sea life that would be helpful in building guidelines and making this type of

energy safe and clean and respectful to place and living things in the future. This should be a

prerequisite to licensing.

There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in

some form or other surely mitigation has to be part of the licensing requirements since the area

around it is a migration path for cetaceans and protected bird species, home to seals and other

species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near

shore, and the size of the proposed turbines has environmental consequences that are difficult to

comprehend. How much concrete will be poured into this area and how much of the sand banks will

be destroyed during the construction phase?

http://www.dublinbayconcern.ie/component/acymailing/url/subid-830/urlid-18/mailid-28?no_html=1

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Job Creation?

We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job

creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this

year saying that “In these financially straitened times, we think it unwise to make consumers pay,

through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind

turbines”.

There is growing consensus in the UK that onshore and offshore wind farms have been a massive

waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart,

killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial

accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive

tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the

total energy generated each day by wind has yet to reach half a per cent worldwide

Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a

scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12

months to the end of February, double the £65million it received for the electricity it produced. It

employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every

member of staff.

The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in

Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The

foundation predicts its Renewables Obligation subsidy in its first year of full operation will be

£160million — effectively £1.77million per job.

We will leave the last word on the cost of near shore wind farms to Minister Rabbitte….

18 JANUARY 2012

Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says

Minister Pat Rabbitte

At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural

Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am

confident that Ireland has the capability to achieve its targets for domestic renewable electricity from

the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently

costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is

about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice

available to me that we can make our targets from the development of onshore capacity, biomass

and related technologies."

http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2)

Visual Impact



18

The visual impact of these enormous turbines cannot be understated. We are famous worldwide

for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines

that deliver no economic or environmental benefit to Irish citizens is beyond comprehension.

In the UK recently David Cameron responded to campaigners who have said that the planning

system remains loaded in favour of developers and that too little of the countryside is protected

from their spread. He signalled that local people would have more say over wind farms in their

areas. Developers would have to offer much greater compensation for building them, and planners

will be compelled to take into account their visual impact and the views of locals. We would call on

the Irish government to do the same.

To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is

160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is

only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of

tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and

all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique

visual that is Dublin Bay.

Conclusion:

The Dublin Array proposal for this massive scale project is completely inappropriate and would

gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire

character of the bay would be destroyed, visually as well as environmentally and at just the time

when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of

Dublin Bay for the million and more people living in this area and those visiting it would be

extremely negative and would cause irrevocable damage, destroying the integrity and value of this

irreplaceable resource.

The Dublin Array website abounds with promises of job creation, security of energy supply, meeting

renewable energy targets and national economic benefits ,with no data to support these statements

http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array

is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the

capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the

necessary permissions for Eirgrid connections have not yet been granted for this project, for the

above reason. Dublin Array will therefore be effectively part of the UK grid but located in an

environmentally sensitive area of Irish near shore.

On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to

safeguard our bay from highly unsuitable developments and developments that provide no benefit

to the Irish people in terms of energy supply, employment or profit and where public consultation is

extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go

some way to improving public and community consultation in future projects.

The recent granting and subsequent surrender of the foreshore license by Providence Resources, the

SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness



19

amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving

and protecting this beautiful, delicate and vital natural amenity for present and future generations.

Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore

legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to

reform this important area.

The government must safeguard the maritime environment that we are privileged to have

surrounding us and ensure proper planning and development is established in this area.

The government has an obligation to implement and uphold the Aarhus Convention, to truly engage

with communities on issues that are of vital importance to them. There is currently a case before the

High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment

and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the

Aarhus Convention, which requires access to information, public participation and access to justice

to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland

until that case is over.

Finally, we call on the Minister to refuse the subject application on the grounds that to make a

decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal

would be premature. It is understood that the Department is undertaking a major review of

licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no

developed policy on renewable energy, large wind farms such as the subject of this application nor

oil or gas exploration and extraction such as the recent Providence application at inshore locations

(i.e., locations where such activity is likely to result in more significant impacts on residential

populations, on important coastline habitats and on coastal leisure, fishing and tourism activities).

In the absence of such defined policy, there is no basis on which to make a decision on the subject

application.

Yours Sincerely,

Submission No. 60





Background:




20














Some interesting figures from Failte Ireland on Dublin:

○ Dublin attracts more tourists than any other county in Ireland.

○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011

○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin.

In a Failte Ireland survey on the most important reasons for visiting Ireland:

○ Beautiful scenery ranked 3rd (after friendliness and safety)

○ Natural attractions ranked 4th

○ Unspoilt environment ranked 6th.

○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%.













habitats directive.


21

































Job Creation?





22


turbines”.











member of staff.






18 JANUARY 2012












Visual Impact






23













Conclusion:



























24






















application.

Submission No. 61

I am in favour of this development, we need all the wind energy we can get and it should be

generated as close to the area the power will be used as possible.

Hi all, If you are as shocked and dismayed at the proposal to construct 145 huge turbines between

Howth and Bray Head as I am, I urge you to make a submission to the Department of the

Environment before the deadline which is 5pm next Friday 28th June. I attach a suggested wording

which you can adapt as you wish. The submission should be sent by e-mail soonest.

To the Department of the Environment, Community & Local Government

Re: Application by Dublin Array for a Foreshore Lease to construct a wind farm on the Kish and Bray

Banks

Dear Sirs,

I wish to object to the above application on the following grounds:

25

(1)The size and scale of the proposed development is excessive. It will be 17km long and comprise

145 turbines 160m high

(2) The proposed development will have a significant and negative impact on the shoreline views

from Howth to Bray Head.

(3) the land and seascape will be industrialised to the detriment of the culture and heritage of the

area, tourism etc

(4)there will be degradation of the protected sea banks with knock on effects resulting in coastal

erosion.

(5)There will be long term adverse effects on marine wild life birds etc

(6)The granting of any such licence would be in breach of EU environmental Legislation.

Please acknowledge receipt.

Yours sincerely

Submission No. 62

To:

Foreshore Consultation

Marine Planning and Foreshore Section

Department of the Environment, Community and Local Government

Newtown Road

Wexford

email: [email protected]

From:

Dear Sir/Madam:


Dublin Arraywind farm project on the Kish Bank (MS53/55/L1)



Background:












mailto:[email protected]

26

































We recommend that existing offshore wind farms introduce a system of data collection with regard

to birds and sea life that would be helpful in building guidelines and making this type of energy safe

and clean and respectful to place and living things in the future. This should be a prerequisite to

licensing.

http://www.dublinbayconcern.ie/index.php?subid=623&option=com_acymailing&no_html=1&ctrl=url&urlid=18&mailid=28

27








Job Creation?





turbines”.











member of staff.






18 JANUARY 2012








28





Visual Impact






from their spread.He signalled that local people would have more say over wind farms in their areas.

Developers would have to offer much greater compensation for building them, and planners will be

compelled to take into account their visual impact and the views of locals. We would call on the Irish

government to do the same.





all its unparallelled natural beauty. If Dublin Array goes ahead we will have destroyed the unique


Conclusion:












capacity to utilise the vast majority of the energy generated by this array .To our knowledge, the








29






















would be premature. It is understood that the Department is undertaking a major review of licensing

and leasing procedures under the Foreshore Acts. It is further understood that there is no developed

policy on renewable energy, large wind farms such as the subject of this application nor oil or gas

exploration and extraction such as the recent Providence application at inshore locations (i.e.,

locations where such activity is likely to result in more significant impacts on residential populations,

on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence

of such defined policy, there is no basis on which to make a decision on the subject application.

Submission No. 63

I suggest Dalkey for the big wind farm

It may help make those guys real .

They have one Toma who comes on a daily basis but is bussed out in evening .he washes rain rovers .

E

Sent from my iPhone

On 27 Jun 2013, at 08:20, "xxxxxxxx wrote:

30

I am in favour of this development, we need all the wind energy we can get and it should be

generated as close to the area the power will be used as possible.

Sent from my iPhone

On 26 Jun 2013, at 23:52,

Hi all, If you are as shocked and dismayed at the proposal to construct 145 huge turbines between

Howth and Bray Head as I am, I urge you to make a submission to the Department of the

Environment before the deadline which is 5pm next Friday 28th June. I attach a suggested wording

which you can adapt as you wish. The submission should be sent by e-mail soonest.

[email protected]

To the Department of the Environment, Community & Local Government

Re Application by Dublin Array for a Foreshore Lease to construct a wind farm on the Kish and Bray

Banks

Dear Sirs,

I wish to object to the above application on the following grounds:

(1)The size and scale of the proposed development is excessive. It will be 17km long and comprise

145 turbines 160m high

(2) The proposed development will have a significant and negative impact on the shoreline views

from Howth to Bray Head.

(3) the land and seascape will be industrialised to the detriment of the culture and heritage of the

area, tourism etc

(4)there will be degradation of the protected sea banks with knock on effects resulting in coastal

erosion.

(5)There will be long term adverse effects on marine wild life birds etc

(6)The granting of any such licence would be in breach of EU environmental Legislation.

Please acknowledge receipt.

Yours sincerely

Address

Submission No. 64


To:



31



Newtown Road

Wexford


From:

Name:

Address:



Yours faithfully

Submission No. 65

From:

Address:





Background:












32



























habitats directive.




33














impacts associated with this industry (www.environmentalexchange.info

) companies. This site is a voluntary site for wind energy companies who are interested in the

effects of turbines on the environment. The contents of the website are not encouraging. It is not

easy to find out about the effect or recent studies on effects of wind turbines on the environment. It

is obvious from this that these companies need help and guidance and rules in order to care for and

be interested in the effects of their developments.












Job Creation?





turbines”.


34











member of staff.






18 JANUARY 2012











http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2

)

Visual Impact









35









Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and

would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire








http://www.dublinarray.com/benefits.html

. It is also clear that electricity generated from this array is primarily destined for the UK grid as

Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the

energy generated by this array .To our knowledge, the necessary permissions for Eirgrid

connections have not yet been granted for this project, for the above reason. Dublin Array will

therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish

near shore.















36



















application.

Submission No. 66


To:



Department of the Environment, Community and Local Government Newtown Road Wexford


From

Name:

Address:

I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) see Submission below: SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1)


37

Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%.

38

These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland.


habitats directive.
















39



















Job Creation?





turbines”.











member of staff.



http://www.environmentalexchange.info/

40




18 JANUARY 2012


Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for

Communications, Energy & Natural Resources, outlined the Irish Government's position with regard

to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for

domestic renewable electricity from the onshore wind projects already in the existing gate

processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy

compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice

as expensive. I am satisfied, on the best advice available to me that we can make our targets from

the development of onshore capacity, biomass and related technologies."


Visual Impact
















Conclusion:







41







































42




application.

Submission No. 67





Background:


























43













habitats directive.
























44












Job Creation?





turbines”.











member of staff.






18 JANUARY 2012



45










Visual Impact
















Conclusion:

















46

































application.

Submission No. 68


To:


47



Newtown Road

Wexford


I am a Dubliner who has campaigned all my life to improve the city for the benefit of all. In recent

years I have become particularly interested in bio diversity and the protection of the natural

environment. Recently I attended an event in Howth at an indoor location where I could enjoy

beautiful views of Dublin Bay, down to Wicklow. This enhanced my appreciation of how fortunate I

am to love in close proximity to this area of outstanding natural beauty in its current state. The new

Dublin Bay cruises are allowing more locals and tourist to experience the sheer wonder of the

habitat and sea and landscapes which we are very fortunate to have in close proximity to a capital

city. When I fly to cities like Frankfurt, what amazes me is how they have also managed to preserve

so much green space as a protective ring around their city. The health and wellbeing, psychological,

exercise, educational and other benefits of preserving areas of untouched natural environment

around major cities could be calculated in monetary terms if they were identified and valued

sufficiently. Government is beginning to recognise the ill effects of lifestyles which deprive people of

exercise, fresh air and contact with nature. Just at this time, Dubliners are rediscovering their needs

to explore their natural environment more. Dublin City Council recently held bio diversity days, and

are developing a Dublin Bay cycle path and focusing on conservation of nature within and around

the city. This proposal would affect people in several counties and nationally as the entire Dublin

region is a focus for visits from people living elsewhere on this island as well as visitors from our

neighbouring island and other parts of the world.

In addition to our own human needs, we have duties to ensure that other creatures are not harmed

by our construction projects or efforts to meet our energy needs. Energy is not only 'green' if it

comes from nature, but also if it does not disrupt the habitat of other creatures and the existing

patterns of the natural environment in which it is proposed to extract it. Wind farms on this scale

placed in such a sensitive location which is a habitat for species which belong in to the Dublin area

and provide leisure and tourism potential for humans, need detailed research and analysis to make

the judgement as to whether they are viable, useful and beneficial to all concerned, including the

delicate balance of the natural environment. I am writing to support the submission from Dublin Bay

Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1)



Background:




48



































habitats directive.


49



It is our view and the view of other groups, including The European Platform against Wind farms





“Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird

























Job Creation?





50


turbines”.











member of staff.






18 JANUARY 2012












Visual Impact








51











Conclusion:






























52



















application.

Submission No. 69

To:




Newtown Road

Wexford






Background:

53





























54










habitats directive.























55












Job Creation?





turbines”.











member of staff.






56

18 JANUARY 2012












Visual Impact
















Conclusion:








57






































58


application.

Yours

Submission No. 70




Newtown Road

Wexford


Dear Sir/ Madam,


Dublin Array wind farm project on the Kish Bank (MS53/55/L1) as follows:



Background:


















○ Dublin attracts more tourists than any other county in Ireland



59

○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin















IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were

the highest recorded anywhere in Ireland.


habitats directive.








‘More knowledge and experience are needed before definite conclusions on impacts can be

drawn'.






60





















Job Creation?





turbines”.











member of staff.


61






18 JANUARY 2012





confident that Ireland has the capability to achieve its targets for domestic renewable electricity

from the onshore wind projects already in the existing gate processes", he said. "Offshore wind

currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind

which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best

advice available to me that we can make our targets from the development of onshore capacity,

biomass and related technologies." (http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2)

Visual Impact
















Conclusion:





62








































63





application.

Submission No. 71

The Minister for Environment, Community & Local Government

Department of Environment, Community & Local Government,

Marine Planning & Foreshore,

Newtown Road,

Wexford

Co Wexford. 25th June 2013

Re: Application for Foreshore Leases. Ref: MS53/55/L1.

Dear Minister,

I wish to object to the granting of the above leases on the following grounds:-

1. There would be significant adverse visual impact on protected and preserved views and prospects

which are listed for protection in local area development plans in Dun Laoghaire Rathdown and

Wicklow. The development would cover an area of 54km2 and would be visible from North Dublin to

Wicklow. It would have the potential to impact on eighteen sites designated or candidates for

designation as Special Areas of Conservation or Special Protection Areas.

2. The expected adverse impacts on the Dublin Bay Natura 2000 site are detailed in the submission

on behalf of the Irish Whale and Dolphin Group. The Group is dedicated to the conservation and

better understanding of whales, dolphins and porpoise in Irish waters.

3. The assertions re job creation and value for money are vague unsubstantiated and inadequate.

4. Misleading information is presented with regard to the electricity which would be generated.

Dublin Array state (RDS display) that "when fully operational, the wind farm will be capable of

generating at least 520MW of clean energy". On average wind turbines generate between 15% and

30% of their maximum capacity. For example, a 3MW turbine generates less than 1MW. It may be

true that “the wind farm will be capable of” generating X amount of energy, but in the real world

this will never happen. The wind doesn’t always blow, when it does blow it doesn’t always blow at

the optimum speed. It is generally accepted that approximately one third of maximum capacity is

actually generated.

5. The Irish east coast landscape would be sacrificed, in order to provide energy to the UK.

6. Ireland has no proper up to date system of planning for foreshore leases. As is stated by the

Coastal Concern Group, a proper democratic planning framework must be put in place to protect our

precious and coasts and seas. I strongly support this.

64

The Minister is charged with the responsibility for granting or refusing leases on behalf of the public

and is required to make the decision “in the public interest”. I do not believe that it is in the public

interest to grant the foreshore leases in this instance.

Submission No. 72




Newtown Road

Wexford






Background:












Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011

../../?acm=1098_28%22mailto:[email protected]%22

65

○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission:






habitats directive.


We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Windfarms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal.



“Whilst research is ongoing on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. "

66



















Job Creation?





turbines”.











member of staff.


67






18 JANUARY 2012












Visual Impact
















Conclusion:







68

















The recent granting and subsequent surrender of the foreshore license by Providence Resources,

the SAC proposal designation and the Marine Area Development Bill has raised a new level of

awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to

conserving and protecting this beautiful, delicate and vital natural amenity for present and future

generations.






















69



application.

Submission No. 73

To:




Newtown Road

Wexford






Background:



















../../?acm=931_28%22mailto:[email protected]%22

70




















habitats directive.














71





















Job Creation?





turbines”.











member of staff.


72






18 JANUARY 2012












Visual Impact
















Conclusion:







73











































74


application.

Submission No. 74

To:




Newtown Road

Wexford






Background:


















○Dublin attracts more tourists than any other county in Ireland.

○According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011


75

○In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin.


○Beautiful scenery ranked 3rd (after friendliness and safety)

○Natural attractions ranked 4th

○Unspoilt environment ranked 6th.

○The percentage of tourists whose expectations were satisfied ranked between 91 and 93%.













habitats directive.
















76



















Job Creation?





turbines”.











member of staff.






77


18 JANUARY 2012












Visual Impact
















Conclusion:









78







































Submission No. 75


79

To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) I object strongly to this proposed project which, like the proposed oil rig, once again highlights the inherent inadequacies of the Irish government and it's infrastructures to deal properly with the issues at hand. It is time for this government to listen and take a stand with the people to ensure that we use the best technologies available and to follow best practices and turn around what seems to be a vicious circle of apathy and quick fix strategies. The future security and well being of all and everything in this country depends on sound judgements and forward thinking strategies. SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors.


80

Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal.

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An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide


82

Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay.


83

Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over.


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Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 76 Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1). Let me please preface my support for this organisation by saying that asthetically I like wind farms (like the one down in Kilmore Quay). I think they are mesmerizing and relaxing to look at. However, I have huge concerns on the impact for the environment in this case. I swim in Forty Foot year round and see, first hand, the beauty of our sea life and how far we have come in cleaning up the bay. SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay

85

Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn

86

“Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff.


87

The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource.



88

The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 77



89

Attention Dept. of the Environment Community & Local Government We the undersigned wish to object to the granting of a Foreshore Lease on the following grounds 1.The size and scale of the proposed development is excessive. It will be 17km long and comprise 145 turbines 160m high. 2. The proposed development will have a significant and negative impact on the shoreline views from Bray to Howth. 3. The land and seascape will be industrialized to the detriment of the culture and heritage of the area, tourism etc. 4. There will be degradation of the protected sea banks with knock on effects resulting in coastal erosion. 5. There will be long term adverse effects on marine wild life, fish, mammals, birds etc. 6. The granting of any such licence would be in breach of EU Environmental Legislation Submission 78


Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected]

I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1)

SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1)

Background:




The group was formed in the wake of the application for a foreshore licence made in January 2012 by

Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well

drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence,


90


application typified the problems inherent in the existing system for the regulation of development of

the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for

environmental issues and uncertainty for investors.











○ Beautiful scenery ranked 3rd

(after friendliness and safety)
















habitats directive.




91


















these companies need help and guidance and rules in order to care for and be interested in the effects

of their developments.






some form or other surely mitigation has to be part of the licensing requirements since the area around

it is a migration path for cetaceans and protected bird species, home to seals and other species that

have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the

size of the proposed turbines has environmental consequences that are difficult to comprehend. How

much concrete will be poured into this area and how much of the sand banks will be destroyed during

the construction phase?

Job Creation?





turbines”.



killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing

industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and

radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all

this, the total energy generated each day by wind has yet to reach half a per cent worldwide


92





member of staff.






18 JANUARY 2012



At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy &

Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I

am confident that Ireland has the capability to achieve its targets for domestic renewable electricity





biomass and related technologies."


Visual Impact

The visual impact of these enormous turbines cannot be understated. We are famous worldwide for

the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that

deliver no economic or environmental benefit to Irish citizens is beyond comprehension.

In the UK recently David Cameron responded to campaigners who have said that the planning system

remains loaded in favour of developers and that too little of the countryside is protected from their

spread. He signalled that local people would have more say over wind farms in their areas.

Developers would have to offer much greater compensation for building them, and planners will be

compelled to take into account their visual impact and the views of locals. We would call on the Irish

government to do the same.







Conclusion:



93



character of the bay would be destroyed, visually as well as environmentally and at just the time when

the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin

Bay for the million and more people living in this area and those visiting it would be extremely

negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable

resource.



http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this

array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have

the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the

necessary permissions for Eirgrid connections have not yet been granted for this project, for the above

reason. Dublin Array will therefore be effectively part of the UK grid but located in an



safeguard our bay from highly unsuitable developments and developments that provide no benefit to

the Irish people in terms of energy supply, employment or profit and where public consultation is










The government must safeguard the maritime environment that we are privileged to have surrounding

us and ensure proper planning and development is established in this area.





Aarhus Convention, which requires access to information, public participation and access to justice to

challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until

that case is over.












94

Submission No. 79 : PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] Dear Sir or Madam I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland.


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○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Windfarms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are

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operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job.


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We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte

At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our



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knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application.

Submission No. 80

To: Foreshore Consultation Marine Planning and Foreshore Section

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Department of the Environment, Community and Local Government Newtown Road Wexford

I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1)

SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1)

Background:

Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage.

The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors.

Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore.


Dublin attracts more tourists than any other county in Ireland.








These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation.

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Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission:

The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland.

In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive.


We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal.



“Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. "

An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments.

We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near


101

shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase?

Job Creation?

We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”.

There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide

Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff.

The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job.

We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte

At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies."

http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact

The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension.



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In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same.

To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay.

Conclusion:

The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource.

The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore.

On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects.

The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations.

Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area.

The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area.



103

The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over.

Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application.

Submission No. 81 For the attention of

Secretary General,

Department of the Environment,

Community & Local Government,

Custom House,

Dublin 1. Thursday, 27 June 2013

Re: The Proposed Offshore Dublin Array on the Kish and Bray Banks.

Dear ,

On behalf of my constituents in Dublin Bay North Constituency I wish to strongly object to the

proposed offshore Wind Farm on the Kish and Bray Banks known as the Dublin Array. I have received

many emails and phone calls from constituents who are opposed to the project and some

constituents are distraught at the prospect of 145 giant wind turbines towering up to 160 metres

just 10km off the south side of Dublin Bay, Dún Laoghaire and North Wicklow.

During the 29th Dáil I was the Spokesperson on Energy for the Labour Party and I was supportive

(and continue to be) of sustainable and renewal energy resources for Ireland. On behalf of the

Labour Party I studied the cost benefit analyses of onshore and offshore wind power and supported

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a role for wind in supplying the national grid. However I believed wind power development could

become far too costly vis-a-vis other possible renewables, gas and even nuclear when all costs

(including environmental degradation) were factored in.

-2-

The location of turbines I believed then and now was a key element in the cost of wind. In that

context I have no doubt that the proposed location of the Dublin Array would be incredibly costly

and damaging to the environment of our capital city and should in no circumstances proceed at the

locations proposed. I will briefly outline my key concerns below.

The Disastrous Visual Impact of the Proposed Wind Farm at the Kish and Bray Banks Is An

Insuperable Obstacle to the Project proceeding

I have carefully studied the Environmental Impact Study for the Dublin Array and noted the

comments made in Vol. 2, Addendum, Appendix E, Visuals (2013). I have also looked at the

Environmental Impact Study Vols. 4 and 5 (ZTV Maps, 2013) and Photomontages (2013). There is a

lengthy discussion on ZTV photo and map principles in the planning literature and I believe that (as

often in planning) the photomontages presented in the Howth Library and elsewhere do not give a

true picture of the appalling impact of the 145 turbines. But even the photomontages in the

application show the visual environment of Dublin Bay and environments from North Fingal down to

Mid-Wicklow are being utterly ruined by the proposal. The annual millions of visitors to Fingal,

Dublin, Dún Laoghaire Rathdown and Wicklow seaside towns and resorts from Balbriggan down to

Greystones and beyond come to view the tranquillity and open space of the wonderful maritime

landscape. The Dublin Array would on completion transform that landscape into an industrial

environment, analogous to the Airport and other industrial zones around the north, west and

southern perimeters of our capital city.

-3-

The negative costs to local tourism and recreation could never be recouped and would essentially

destroy Dublin Bay and environs as an amenity for my constituents and indeed all the people of the

Dublin Region.

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Some of the photomontages from Howth and Dún Laoghaire are truly shocking and make one

wonder why this project proceeded even to it's current stage.

I have examined other offshore locations in Europe and the Dublin proposal seems particularly close

to the shoreline and therefore provides a uniquely bad challenge to the visual landscape. I note e.g.

that the London Array which generates 630 MGW's and has 175 turbines lies (at the closest 18 km or

12 miles) from the Kent and Essex coasts on the Long Sand and deep Knock sandbanks. The turbines

there stand 285 feet above the water but according to visiting journalists and engineers are much

less intrusive on the landscape from the shoreline than the Dublin Array will certainly be.

A similar proposal to the Dublin Array is the Cape Cod, Massachusetts USA Cape Wind project. The

giant turbines will be about 8.5 km offshore and the photomontage views of the Cape Wind turbines

at distances from 8.6 km to 21.9 km are truly disastrous. At a planning stroke, the wonderful

environment of the Massachusetts coastline is transformed into a vast industrial network and the

visual amenity of the area would be lost forever. The Dublin Array will produce a similar result for

Dublin Bay and our east coast.

-4-

A study sponsored by the U.S. Department of the Interior’s Bureau of Ocean Energy Management

(BOEM), Argonne National Laboratory’s Environmental Science Division (EVS) and the University of

Arkansas Center for Advanced Spatial Technology (CAST) conducted an assessment of the visibility of

offshore wind facilities which were located in the U.K. The observed facilities were located in the

Irish Sea near Liverpool, the North Sea near Skegness, and in or near the Thames estuary. The

facilities ranged in size from 25 to 140 turbines and were located from 3.4 to 32.3 miles (5.5 to 52

km) of the viewpoints. Results showed that under reasonably favourable viewing conditions, small to

moderately sized facilities were visible to the unaided eye at distances greater than 26 miles (42km)

with turbine movement visible up to 24 miles (39km). Observed wind facilities were judged to be a

major focus of visual attention at the distances up to 10 miles (16 km), were noticeable to casual

observers at distances of almost 18 miles (29km) and were visible with concentrated viewing at

distances beyond 25 miles (40km). The above wind turbine visibility and visual impact threshold

distances clearly show that the Dublin Array will industrialise and destroy the maritime landscape of

Dublin Bay and environs and the project must be abandoned at the close-to-the shoreline location

proposed.

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Planning Legislation and Regulation for Offshore Development is Totally Lacking and Grossly

Deficient

The evolution and presentation of the Dublin Array proposal graphically illustrates the grave lacunae

in Irish Law and regulation regarding our offshore resources and amenities.

-5-

During the boom, developers were awarded foreshore leases for two of the biggest offshore wind

farms in the world off Ireland’s east coast under outdated and defunct legislation (The Foreshore Act

1933) on the authority of the Minister for the Marine. The Dublin and Wicklow local authorities

concerned were not involved, there were no Strategic Environmental Assessments to evaluate

cumulative impacts, no central national plan for Ireland’s coastline and no comprehensive,

independent cost benefit analysis. The large-scale wind farms on the Arklow Bank and Codling Bank

will have major cumulative impacts of the Wicklow coastline.

Under the Foreshore Act 1933, the Minister has sole discretion to award foreshore leases for

developments at sea. The lack of statutory involvement by the local authorities concerned and of the

right of appeal against the Minister’s decision is in contravention of Directive 2003/35/EC. It is

strongly argued by the Coastal Concern Alliance and other Irish environmental campaigners that

nobody has responsibility in law for protecting the seaward side of Ireland’s wonderful coastal

landscapes. There is grave concern that the applications for the 364 MW Dublin Array of 145

turbines, the 320MW Oriel Wind Farm in Dundalk Bay of 55 turbines, the 1000 MW Codling 2

proposed off Bray Head (200 turbines and 100 MW Galway Bay wind farm (20 turbines) could be

progressed to completion in a total legal and regulatory vacuum which will destroy a significant part

of our coastal landscape and marine biosphere heritage.

-6-

It is notable too that the valuable 99 year leases for the Arklow Bank and Codling Bank facilities were

sold on in 2008 by the original Irish developers, Airtricity /NTR and Treasury Holdings /Fred Olsen

Renewables. So the Coastal Concern Alliance argues that 120 km sq. of our Wicklow Coastal waters

were transferred to private foreign energy interests. Many people believe that former Green

Minister Eamon Ryan exacerbated these problems by announcing very significant price supports for

offshore wind energy while he and former Minister John Gormley totally failed to protect Ireland’s

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coastal resources with new major legislation. Without such legislation and accompanying regulation,

projects like the Dublin Array are hopelessly premature and should not be approved.

Grossly Deficient Cost Benefit Analysis of the Dublin Array and Wind Power generally

The Programme for Government of the current government undertook to carry out ‘proper cost-

benefit analysis and evaluation’ of all major capital projects. Coastal Concern Alliance and many

others argue that this has never been carried out for offshore wind farm proposals such as the

Dublin Array. No Strategic Environmental Assessment (including cost benefit studies) to monitor the

cumulative impact of wind farms on highly sensitive locations like the Kish and Bray banks have ever

been carried out and are not present in the Environmental Impact Study submitted for Saorgas

Energy Limited by MRG Consulting Engineers Limited.

-7-

Coastal Concern Alliance e.g. believes that a 12 nm (22.5km) buffer zone free from 160 metre high

turbines and blades should be introduced around the Irish coast. Developers such as those

promoting Dublin Array will oppose this and insist on the 5 to 10km distance to the Kish and Bray

banks. They oppose moving further out into the Irish Sea because only the near-land and sandbank

conditions close to the shoreline make the economics of their proposal remotely viable. But their

proposal is also hopelessly uneconomic when the costs of the damage to the visual environment and

marine ecosystem are also factored in. Indeed only a 12nm (22.5km) buffer zone could hope to

alleviate some of the above damage and even at that distance, turbines would blot the landscape.

The broader problematic economics of wind power are nowhere addressed in the Dublin Array

Environmental Impact Study. Significant extra costs of energy to consumers resulting from

unsustainable wind farm costings are totally ignored. The site selection criteria in the MRG

Environmental Impact Study conveniently ignores the damage to the adjoining land visual landscape.

But the socio-economic benefits outlined are very meagre for this immense development. Only 250

full-time equivalent jobs are claimed for the completed project, in effect less jobs than a small to

medium sized shopping centre or an SME enterprise centre.

-8-

In the U.K. it is estimated that for the year 2012, a little over £1.2 billion was paid out to wind farms

through consumer subsidies financed by a supplement on consumer electricity bills. But the whole

U.K. wind farm industry employed just 12,000 people in 2012 which means that each of those jobs

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cost consumers €100,000, a truly incredible figure. U.K. energy economists estimate that the subsidy

figure will rise to £6 billion by 2020 with landowners and farmers earning an average £40,000 per

annum for turbines located on their land. It has been further estimated that the 100 people working

for the greater Gabbard wind farm company in Lowestoft, Suffolk secure a subsidy of £129 million,

meaning a cost of an astonishing €1.29 million per job. Of course the intermittent and non-

dispatchable nature of wind farms make the basic economics of offshore wind farms even more

crazy. Others have long noted also that the turbines and blades and related jobs are overwhelmingly

based in Denmark and Germany. Indeed by late 2010, the Danish wind turbine manufacturers

Siemens Wind Power and Vestas had installed 91.8% of the world’s 3.16 GW offshore wind power

capacity.

Finally, an old joke in Irish energy circles was that Ireland’s nuclear power programme would be

based in Wales and Northern England. With the development of the new Irish Sea interconnectors

and the possibility of large exports of wind generated electricity to Wales and England, our British

neighbours could now also joke in response that their ugly wind power turbines will happily be

based in Dublin Bay and along the Wicklow coastline.

-9-

The Analysis of Impacts to the Marine Biosphere in the MRG Consulting Engineers Ltd. Report is

also Gravely Deficient

As U.K. fishermen have long noted, offshore wind farm promoters tend to try to locate at the same

maritime sites which have long supported fishing and the rich and diverse marine biospheres

necessary to sustain it. This is again true for the Kish and Bray banks. The colossal impact of the High

Scenario OREDP (Offshore Renewable Energy Development Plan) of producing a large part of 4,500

MW of offshore wind on the fragile and changing sea environment is not remotely investigated by

the Environmental Impact Study. In particular the environmental noise, water quality, climatic and

other impacts on bird and marine life are not properly evaluated by the proposers who award

themselves a “Low potential impact” designation impact on the 45 key bird species. But it seems

clear that studies at existing U.K. offshore and onshore wind farms have shown major impacts on

bird life.

Likewise the impacts on marine ecology identified by Ecoserve for the promoters seem a very

minimal conclusion (at foundation areas of the turbines). I note that significant remedial measures

(such as cofferdams) are recommended to protect Ireland’s unique sea mammals but government

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policy on conservation of these animals since 1991 surely alone rules out the possibility of the Dublin

Array.

-10-

Finally it is striking that the Environmental Impact Study concludes that “appropriate mitigation

measures” will be essential to permit the Dublin Array to proceed. Many constituents believe

however that such environmental mitigation measures are impossible, given the problems with the

proposals.

On the above grounds, my constituents and I are strongly of the view that the Dublin Array should

not proceed.

Yours sincerely

---------------------------------- Thomas P. Broughan Dublin North East Labour T.D.

Submission No. 82 To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1). Submission No. 83 Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford

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Dear Sir / Madam I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) I am appalled by the lack of meaningful public consultation on this and other license applications for the development of our national energy resources. The level of public awareness of this license application is minimal and only through the hard work of dedicated volunteers are the public being informed on any meaningful level. Not only is our planning system in drastic need of change, a coherent visionary strategy is required at government level to develop our energy resources for the betterment of the people of Ireland and not corporations seeking to extract profit at the peoples expense. Submission No. 84 To the Department of the Environment, Community & Local Government Re Application by Dublin Array for a Foreshore Lease to construct a wind farm on the Kish and Bray Banks Dear Sirs, I wish to object to the above application on the following grounds: (1)The size and scale of the proposed development is excessive. It will be 17km long and comprise 145 turbines 160m high (2) The proposed development will have a significant and negative impact on the shoreline views from Howth to Bray Head. (3) the land and seascape will be industrialised to the detriment of the culture and heritage of the area, tourism etc (4)there will be degradation of the protected sea banks with knock on effects resulting in coastal erosion. (5)There will be long term adverse effects on marine wild life birds etc. (6)The granting of any such licence would be in breach of EU environmental Legislation. Submission No. 85

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Dear Sir/Madam, I am concerned about the proposed Dublin Array Wind Turbine Farm off the Irish Coast and would like to make a submission. I object to this wind farm on the following grounds: 1. Visual Pollution: one must bear in mind the need to maintain the unique and unspoilt natural beauty of Ireland's land, coast and out-to-sea vista. The amount of wind turbines in one place will make the Irish Sea look like an industrial park. 2. The negative impact this wind farm could have on sea-life and bird-life (noise, vibration etc.) 3. The effect of mining and drilling on the sea bed, and possible side effects also on land (for example minor earthquakes, especially as there are often earth tremors in Wales and on the east coast of Ireland). 4. The use of materials needed for light-weight metals for turbine blades which might have to be extracted from mines in other countries. Does our 'progress' have to blight the lives of villagers in African countries, South America or China? Will we be guilty of 'developing underdevelopment'? This is an ethical problem and one we must consider when we want to improve the material quality of our lives - but sadly at the expense of others. There is war and conflict in parts of the world where many precious metals exist which might be needed for the lightweight steel for turbine blades. Also, what is the cost in financial terms of the extraction and transport etc. of necessary minerals? 5. We could design alternative turbine technology to create wind power. Consumers could also contribute to the national grid. Wind and air should not become a commodity appropriated by the few. Buildings, for example could be designed to have mini- turbines attached to rooftops. Villages and towns could have appropriate sites allocated for small wind farms. Submission No. 86 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1)

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SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission:

113

The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase?

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Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected

115

from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the

116

High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 87 To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors.

117

Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal.

118

An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with egard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It

119

employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of

120

Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application.

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Submission No. 88 Department of the Environment, 27th June 2013 Community & Local Government Custom House Dublin 1 Dear Sirs I have read the Environmental Impact Statement submitted by the applicant. I am shocked at the size and scale of the proposed development and I am also shocked that Foreshore Leases have already been granted for large-scale wind farms on the Arklow Bank and the Codling Bank. The Dublin Array proposal is 17km long. Combined with the Codling Bank wind farm it would comprise a continuous line of turbines 35km long. I am deeply concerned at the short and long-term impact the proposal by Dublin Array will have on the environment. The views from Howth to Bray Head will be forever destroyed. The land/seascape will be industrialised, the protected sandbanks degraded and the proposal will have serious consequences for the well-being of marine wildlife and birds. It will also have a severe impact on navigation, fishing and sailing. I strenuously object to the granting of the Foreshore Lease on the grounds set out by Coastal Concern Alliance and as set out by me above. Submission No.89 I AM A PRIVATE INDIVIDUAL WHO SUPPORTS THE APPLICATION AGAINST THE WINDTURBINE ARRAY by DUBLIN BAY CONCERN Subject: Urgent Dublin Bay Concern - Wind Turbine Submission - Deadline tomorrow Urgent! Last two days for windfarm submission Tomorrow, June 28th at 5pm is the deadline for submissions on the proposed wind farm on the Kish Bank. We have prepared the submission below and if you feel that you can support it, you can do so by simply cutting and pasting the details below and sending to [email protected] before the deadline. You can also add your own comments if you wish, all help would be greatly appreciated. We had hoped to meet with Dublin Array earlier this week to ask some questions on this issue and they were to give a presentation to Dun Laoghaire Rathdown County Council on the same day. Unfortunately, when we informed them that we would also be attending the presentation, they felt unable to take part in either meeting, so we are not able to give you an update on this as we had hoped. This lack of public engagement is a common theme that we in DBC have encountered over the last year or so and it is at the heart of what is wrong with development and planning procedures as they are currently carried out.

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We will keep you posted on developments and on behalf of us all thanks for your continued support, RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] OBJECTION TO WIND TURBINE ARRAY KISH BANK APPLICATION I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1). In their submission, which is generally supported, the following is added by way of objection. [1]it has been the practice in the past for an applicant for such a development to then raise capital with/from others who are not part of the original application to give capacity to carry such a development out. This is done after permission is granted where the permission [license] becomes an asset of the original company which may not have the original including capital capacity to carry it out. There are most serious questions as to the legality of such activity where the asset value of the original applicant company can thus be considerably enhanced. Full public evidence must be given of the full capacity for the purported developers to carry out the development inclusive of capital to do it. [2] the capital adequacy of the developers in this instance is questioned and must be supplied in public [3] their individual capability & experience of carrying out such a development is questioned and they have no marine experience purely land developments on their own admission and with the land developments limited. [4] the total wattage of what they are to produce must be produced and the capital cost of each unit and the total development at one time if on a phased basis. This should include the provability of each part which in reality should be able to stand 'on its own minimum size' to produce a profit. Otherwise it can simply become "more and more" or "we will make a loss". [5] a public statement of what partners if any they are considering or have arrangements with to carry out such a development either in outline on in full should be supplied [6]considerable suspicion attached to the distance from a fixed point on land quoted by t hem in various areas is expressed and can be shown to be justified. Some measurements given do not appear to stand up and are contradictory on what is known and has been examined. They should also be expressed in miles as well as kilometres as the public at large have still not got used to the usage of Kilometres as a unit of measurement and e.g. 17 kilometres is not seventeen miles...The measurements of some areas [land to development] are distracting & irrelevant and can be

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misleading in the totality to create an impression eg. land to development array from Portrane of North Dublin which can be misleading in the totality to the public at large. It is questionable even if from Portrane the development could be seen at all since Howth might block the view of the area from Portrane.... What about Portmarnock? Indeed what about the views from Howth itself a major recreation area for Dublin's citizens - Sutton as well. Some measurements from Dun Laoghaire Harbour as a focal point chosen by the Developers do not tally with others on location.ie e.g. from Coliemore Harbour and Killiney Hill. Alleged views from The POINT in the Liffey on a straight line out would not appear to give a view AT ALL to the array since it would be behind Dalkey Hill which would obstruct it. The same would apply from Sandymount. Both are misleading. [7] the proposed development cuts across views from Dalkey Hill and Killiney Bay and down as far as Greystones along the coast and could be seen from the land.Killiney Bay is an area of exceptional natural beauty near a capital city which should be properly protected inclusively of as a Special Amenity Area for which application is to be made. An application is also in consideration and to be prepared to make Killiney Bay a UNESCO World heritage site for conservation etc. and notice is hereby given of both such applications. Some inhabited residential land areas are elevated eg Greystones where thus the array could be seen from these residential areas .An elevation increases the length of vision over a flat surface such as the sea . This does not appear to be referred to.EX 200 feet high gives an increased view at [flat] sea level of ..................? On a clear day from the top of Killiney Hill it is possible to see the mountains of north Wales. Objector did it on Tuesday last [June 25th] where he saw the tops of the mountains while taking photos of Killiney Bay area and surround.. [8] a picture of an assessment of geological substrata RIG put in on display by the Developers is not in the area of the array development but it is in an area where Providence Oil is believed to have found traces of oil and it is believed was retained/hired by Providence oil and not the Developers. This is materially misleading to the public at large. [9] Full public details of any association whatsoever, whether formal or informal with Providence Oil must be made public together with the geographical extent & geographical area of the possible oil and gas reserves. This would be for reasons that work to put in turbines might disclose geological structures or composition which would [greatly] benefit Providence.IT would not be believed that the Developers and Providence have not had contacts and discussions Surveys and drilling by the array developers could almost certainly be to the advantage on supply of information alone to Providence. [10] there has been lack of proper publicity & public information of what is proposed so that the public can know and understand the full and implied implications of such a development which is on what could be called a "major industrial scale" which can be seen from the coastline inclusive of noted beauty spots and residential areas. Bray is one of these, Greystones another, Killiney Bay and surrounds even Sandyford Cherrywood etc. The notice periods are too short and can materially prejudice proper informed objections. [11] All parties to take part in such a development should be publicly identified before any permission is granted .Third parties eg PRovidence must be made to 'declare an interest' particularly if the area extends to a possible area where there are or may be oil or gas reserves even on a 'possibility'..

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[12] As many matters are unsettled inclusive of adequate protection of beauty and recreational spots & amenities and the full implied nature of what such a development would contain or develop to. The Application should be refused outright and at the least an Oral hearing should take place on a proper time frame with adequate notice of it and to allow the public to be properly informed beforehand. In essence there is lack of adequate information inclusive of [given herein] defined fundamental shortcomings and omissions which are centrally material sufficient to refuse such an application in full without what can be a defective Oral hearing on inadequate information inclusively of not being in accordance with EU Environmental laws. This is currently the position and an Oral hearing should not be given on the basis of what the Developers have put in by way of information. An Oral hearing is not a 'fishing expedition' to elicit further [new additional] information.IT is supposed to be on the original application as far as is known. [13] there are indications of breach of EU environmental prescriptions and law in the totality for the development and the manner of seeking to bring it about. A court case has already taken place on this in the High Court by the objectors’ legal advisors. [14] A copy of this submission is also sent to the objectors "Oil at Dublin Bay concern " and permission could be given by them to quote from it if wanted. SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin.

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In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. "

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An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012

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Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the

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above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 90 I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) Submission No. 91 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1)

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To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th

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○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that

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these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity

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from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is

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extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 92 Department of the Environment, 27th June 2013 Community & Local Government Custom House Dublin 1 Dear Sirs I have read the Environmental Impact Statement submitted by the applicant and have noted the photo montages annexed thereto.

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I am absolutely shocked at the size and scale of the proposed development and I am also shocked that Foreshore Leases have already been granted for large-scale wind farms on the Arklow Bank and the Codling Bank. The Dublin Array proposal is 17km long. Combined with the Codling Bank wind farm it would comprise a continuous line of turbines 35km long. I am deeply concerned at the short and long-term impact the proposal by Dublin Array will have on the environment. The views from Howth to Bray Head will be forever destroyed. The land/seascape will be industrialised, the protected sandbanks degraded and the proposal will have serious consequences for the well-being of marine wildlife and birds. It will also have a severe impact on navigation, fishing and sailing. I strenuously object to the granting of the Foreshore Lease on the grounds set out by Coastal Concern Alliance and as set out by me above. Submission No. 94 I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore.

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Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is ongoing on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments

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where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The

137

foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource.

138

The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 95 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1)

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To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th.

140

○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments.

141

We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best

142

advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be overstated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects.

143

The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 96





Background:




144


































145


habitats directive.


































146

Job Creation?





turbines”.











member of staff.






18 JANUARY 2012












Visual Impact

147
















Conclusion:

























148






















application.

Submission No. 97 Sent from my iPhone Begin forwarded message: Date: 27 June 2013 13:31:42 GMT+01:00 To: "[email protected]" <[email protected]> Subject: Proposed Dublin array wind farm RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected]

149

I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation:

150

Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other

151

species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2)

152

Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations.

153

Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 98





Background:










154





























habitats directive.




155































Job Creation?





turbines”.

156











member of staff.






18 JANUARY 2012












Visual Impact










157







Conclusion:





















The recent granting and subsequent surrender of the foreshore license by Providence Resources,

the SAC proposal designation and the Marine Area Development Bill has raised a new level of

awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to

conserving and protecting this beautiful, delicate and vital natural amenity for present and future

generations.






158

















application.

Submission No. 99 I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore.

159

Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments

160

where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The

161

foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource.

162

The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 100 I am a private individual writing to support the submission from Dublin Bay Concern on the proposed


163



Background:































164








habitats directive.































165




Job Creation?





turbines”.






total energy generated each day by wind has yet to reach half a per cent worldwide.





member of staff.






18 JANUARY 2012



At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy &

Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I

am confident that Ireland has the capability to achieve its targets for domestic renewable electricity







Visual Impact

166
















Conclusion:

























167






















application.

Submission No. 101





Background:









168






























habitats directive.


169

































Job Creation?





turbines”.

170











member of staff.






18 JANUARY 2012












Visual Impact








171









Conclusion:






























172

















application.

Submission No. 102 To: Minister for the Environment Re: Dublin Array Wind Farm Dear Minister In relation to the proposed massive wind farm in our foreshore, I would like to know how an application for such a huge scale construction project can be envisaged and considered in the first place. The proposal is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally. The impact for all the users of the bay and the million and more people living in this area and visiting it would be extremely negative. Coastal Concern has brought into focus and have highlighted the inadequacies of foreshore leases and the wind farm issue over 6 years ago. I support Coastal Concern and the work of Dublin Bay Concern in the campaign to safeguard our Bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit. Public awareness and consultation is extremely poor in this area. The Government need to safeguard our foreshore by managing it properly and not permitting large scale development schemes to be proposed in the foreshore in the first place. As our Minister for the Environment I would appreciate you working to ensure our bay is protected by bringing the issues to the government of this Country and committing to make changes that will safeguard the maritime environment that we are privileged to bound and ensure proper planning and development is established in this area. Sent: Monday, 27 May 2013, 10:08 Subject: Re: Dublin Bay Concern - Wind Turbine Submission

173

Dear Councillor, You are probably aware of the application for a foreshore lease for the construction of a large wind farm on the Kish Bank by a Kerry based company Saorgas. Details of the application are to be found here http://www.dublinbayconcern.ie/index.php?subid=934&option=com_acymailing&no_html=1&ctrl=url&urlid=7&mailid=27 and are also on display in Dun Laoghaire library until the end of the public consultation period, June 1st. We have been in touch with Coastal Concern Alliance, who have been working in this area for many years and attach their information leaflet, outlining their concerns in relation to this proposal. Can you please give this matter your urgent attention? This development is not in the best interests of Dublin Bay and those of us living in it. Once again flimsy statements promising job creation, security of energy supply, meeting renewable energy targets and national economic benefits are abounding with no data to support these statements, whilst the environmental risks and the industrialisation of Dublin bay are minimised IN THE SUBMISSION FOR OVER 145 WIND TURBINES IN A 54 SQUARE KILOMETER AREA. As our councillors we are relying on you to act to protect the bay in whatever ways you can. We would ask those of you attending the County Council's Environment and Heritage meeting on Monday 27th May to discuss this matter as a matter of urgency. In addition we request that collectively and individually you make submissions on this matter. We presume that the environment department in the council is an automatic consultee for this proposal. Can you confirm that this is the case and that a submission has been entered? There appears to be confusion on the deadline for submissions but our most recent information is that the date is 7th June 2013, we will confirm as we have more news. Many thanks on behalf of us all at DBC, and we look forward to hearing back from you

Submission No. 102A

MS 53/55/LI

Please view the image below and explain how such an application can be processed by the

Department of the Environment. Is there a screening process whereby developers put forward their

proposal for assessment prior to an application for a lease being made? This proposal is completely

inappropriate. Why did Dublin Array fail to put images on their website the images are tucked away

in local libraries and the vast majority of Irish citizens have no idea that this massive wind farm that

will radically alter Dublin Bay has been submitted.

I ask the Minister to refuse the application and to pay proper attention to conserving the natural

beauty, culture, history, heritage, special amenity nature, special conservation nature of Dublin Bay.

Please protect the intrinsic value of our bay and by far more stringent in the type of projects that

you allow to make lease applications in the first place. This is unfair to the citizens of Ireland l. The

developers who invest in these projects clearly think that they are likely to be successful in their bids

for foreshore leases - please review this whole matter and refer to proper planning and sustainable

development including conservation as a primary objective.

Yours

174

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Submission No. 103 SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety)

175

○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihan’s proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn” “Whilst research is ongoing on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that

176

these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best

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advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking

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to enforce a UN decision that the Daft Irish Renewable Energy Plan is flawed because it does not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application.

Submission No. 104 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory


179

well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive.

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Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Submission No. 106



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Submission No. 107 I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) Submission No. 108 MS 53/55/LI

Dear Minister,

Please review these photos showing detrimental visual impact of proposed massive wind farm on

Dublin Bay. The environmental impacts are unknown. Please refuse this application.

http://www.coastalconcern.ie/cms-assets/documents/AppendixA.pdf

Submission No. 109 Submission to the Department of the Environment. Subject: Proposal for construction of Wind Turbines in Kish Bank. I wish to voice my total objection to the proposal to locate giant wind turbines close to the shore in Dublin bay. This proposal is so hideous that it seems that it must be a joke. However the consequences would be far from funny, namely the despoliation of one of the most beautiful bays in Europe. No civilized country would consider allowing such huge constructions this close to any shoreline, especially in an area of outstanding natural beauty accessible to and treasured by the entire Irish population. Visitors to our shores often comment on the memory of first sailing into this beautiful unspoilt bay and seeing the Irish coastline. The graphic representations of the proposed constructions clearly show the disastrous impact they would have on the environment, completely dominating the delicate beauty of the bay and disrupting the marine life of the area. Yours faithfully Submission No .110 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford

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email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation.

183

Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area

184

around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2)

185


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Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 111 The Department of the Environment, Community and Local Government Marine Planning and Foreshore Newtown Road Wexford Co Wexford Dear Sir/Madam, Please reconsider your plan to erect wind turbines in beautiful Killiney Bay. As a regular visitor to the area, I was upset to hear about the plan and in fact, find it hard to believe that anybody would consider defacing the iconic bay loved by so many visitors as the Naples or Kamakura of Ireland. I trust your colleagues in the Department of Tourism would be able to give you an estimate of the contribution of the area to tourism in our country and the destructive impact wind turbines would have on that tourism and the happiness of the people who live there and visit there. Please listen and think about the consequences before you approve this project.

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Submission No. 112

Re: Kish Bank (MS53/55/L1)

We Wish to object in the strongest possible way to the granting of a license for a wind farm in the

Dublin Bay area.

Submission No. 113 Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011

188

○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. "

189

An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte….

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18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the

191

above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application.

Submission No. 114 Dear Sir/Madam, I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1)

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Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the

193

IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase?

194

Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected

195

from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the

196

High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 115 I would like to register our protest with Lease Application Ref No. MS53/55/L1. I feel the project will seriously undermine the natural beauty and landscape of the coastline and therefore should not proceed. Submission No. 116 I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an

197

abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states:

198

‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff.

199

The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be

200

extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application.

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Submission No. 117 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety)

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○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that

203

these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity

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from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is

205

extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 118 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1)

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SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish

207

Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to

208

comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension.

209

In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area.

210

The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 119 I wish to register my strong objection to this proposed development. My objections are in line with the submission outlined in the Wicklow People newspaper today. I object on grounds of the aesthetic ruining of a large beautiful stretch of our coastline. I also object because of the antiquated, outdated Act under which permission could be granted. Having looked into it at length over a period of time I believe this development would be BAD for this country - environmentally and economically. I think it will be a disgrace to this government if permission is granted. Yours sincerely Submission No. 120 Dear Sirs I have lived and worked in Dublin all my life. During that time (I am now 58) I have enjoyed the many attributes of our city but in particular Dublin Bay. The vista when you see it first coming from Dublin City is breath taking. I have spent much of my life on the water and Dublin Bay is quite spectacular. This current proposal will ruin forever our beautiful seascape. I object strongly to it and sincerely hope it will not be permitted to proceed. Submission No. 121 Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government

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Newtown Road Wexford I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) Submission No. 122 (Refer to submission No. 11 Coastal Concern Alliance for PDF attachment) Dear Sirs We wish to object to the as-proposed Wind farm, and support the submission of the Coastal Concern Alliance, copy attached. Submission No. 123 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore.

212

Some interesting figures from Failte Ireland on Dublin: ○Dublin attracts more tourists than any other county in Ireland. ○According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○Beautiful scenery ranked 3rd (after friendliness and safety) ○Natural attractions ranked 4th ○Unspoilt environment ranked 6th. ○The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Windfarms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed

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morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job.

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We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the

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necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 124 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected]

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I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation.

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Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Windfarms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area

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Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 125 The Minister for the Environment, Community and Local Government Marine Planning and Foreshore Newtown Road Wexford. Dear Minister, Re: Application for Foreshore Leases Ref. MS53/55/L1 I wish to register an objection to the granting of the above leases. The reasons for my objection are set out in the submissions to your department by the Coastal Concern Alliance and other interested parties. Submission No. 126 Whilst I agree entirely that we need to be reducing drastically our use of fossil fuels, and so welcome the introduction of renewable energy, I have great reservations about the proposed wind farm in Dublin Bay. I understand that the economic gain from wind farms anywhere in Ireland is dubious, and I would leave the explanations of this to those more qualified than myself to explain.

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My main concern is environmental. 140 wind turbines stretching from Howth to Wicklow, tall as they are, would be in my view a visual disaster. Ireland relies, and should rightly rely on its outstandingly beautiful and famous sea and landscapes to attract the tourists, who admire here what they have seen nowhere else in the world. 70% of tourists interviewed on the Devon, UK coast said that if the proposed wind farm went ahead off the coast of Woolacombe, it would affect negatively their view of their trip there. I would assume that the same would apply here in Dublin Bay. The Dublin Bay is a jewel, but a quite small one, and 140 wind turbines is an out of proportionately visually disturbing sight, especially so close to shore as the Kish Bank which I understand is the proposed location. Off the Welsh coast near Llandudno, I see 25 turbines. But that bay is relatively vast, and can accomodate 25 turbines. To see 140 turbines in Dublin Bay would be its visual ruination. Besides the visual pollution this would present, would be the likelihood of noise pollution. Nobody seems to know yet the extent of this. I feel we should wait until this has been properly surveyed and measured. I do know of one couple who have just 1 wind turbine imposed near their house, and 24 / 7 they are driven crazy with the noise. Once these turbines are built and positioned, nobody will ever take them away (not like oil or gas rigs which do their job and then leave). The turbines will be there for ever. This couple are unable to sell their house because of the noise. This is not right; and there must be many, many people already in the Midlands of Ireland who will likewise be saddled and stuck. I also understand that the fish, whales, dolphins, porpoises and birds will be seriously discommoded. Whales and dolphins in particular rely on their sonar systems to navigate the waters. If those sonar systems are disturbed, they are at great risk of becoming lost, beached and dying, as seems to be happening with greater frequency as the ecological boundaries of the environment are being breached by man. And again, our dolphins and whales are some of our best tourist attractions. And the fishing industry is already sufficiently threatened to not need more of a threat from turbines. As for the locals, we did not sign on here for big business to ruin everything for us. We are more than happy to share our lovely home with clean, quiet and considerate guests, but not with people who seem to come in from under the radar and take our place over in the absence of a government who appears merely to flutter its eyelids at greedy people, inviting them in, and betraying us, the more vulnerable parts of our society by so doing. If we had built up our tourist industry, as we did in the past, we would surely gradually be able to pay our way now. But we gave in to reckless big business, and so crashed and are in dire straits now. But it would still be possible to do everything necessary to attract the tourists back to Ireland, and introducing a wind farm into Dublin Bay would not be one of them. I would respectfully request that the turbines are placed far further away than in the Kish area. Submission No. 127 I wish to submit a few comments and observations about the proposed large scale development of wind farms off the coast of Dublin and Wicklow.

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I am a 92 7ear old expatriate Australian living in____ with my Irish wife. Our house is situated on the water's edge directly opposite _____. We understand that there are fewer than 100 dwellings with a direct frontage to the sea but are sure many thousands of other Dublin residents will concur in our view that this development would represent gross environmental vandalism. One of the key considerations when appraising a wind farm development, as for a shopping centre, is location, location, location. In this case the location is patently wrong - far too close to the shore and destroying a magnificent marine outlook. Dublin has rightly valued this bit of coastline which has been compared to the Bay of Naples, with evocative road names like Sorrento Road, Vico Road etc. We are sure the Italian Government will not be currently considering sabotaging this priceless asset with an overblown wind farm development. The Dublin Bay project would detract enormously from enjoyment of the rich historical heritage including the Island where the Vikings held their slaves and hostages, the Martello Tower, the Sound which once served a Dublin, port and the Bay sounded by Admiral William Bligh of Bounty fame. The proposal claims that electricity generated by the wind farm could be exported to the United Kingdom, where it would help them achieve targets for renewable sources of energy. The output from Irish wind farm could thus be counted to both Britain's and Ireland's credit. What sort of monitoring does this pre-suppose? As wind generated power is more expensive than that from fossil fuels the Brits would no doubt be glad for Irish taxpayers to subsidise its export. One of the comments sent you has pointed out the risk of lurk merchants (economists term them rent seekers) aspiring to become like ________ multiple millionaires overnight by selling on the licence. A consequence of this could be higher charges for consumers as purchasers of the licence seek to recover their outlay. The employment created by the wind farms during construction and operation is very small in relation to the magnitude of the investment. Of course, the estimates exclude the police jobs to cope with demonstrations against the project. This, mind you, is not a threat - just a reasonable prognostication. We hope the Department will not be stampeded into approving this ill-considered proposal. Submission No. 128 Dear Sir/ Madam, I wish to appeal against the proposal of a wind farm being located in Killiney Bay and Kish Bank by Saorgas Energy Ltd. It is only in the last few days that I have become aware of this project and I fear that many residents and other concerning citizens are unaware of this plan and have therefore no say in the future of their landscape. I understand that wind farms may be the answer to our need in Ireland for sustainable energy but I believe it would be hard to find an area more picturesque than Killiney Bay to build these monstrous wind turbines. The landscape of this country has been dramatically altered over the decades and sadly the beauty of this once rural landscape is rapidly diminishing. I therefore implore you to reconsider the proposed site for the wind farm. The sheer beauty of Killiney Bay and its surrounding area attracts both foreign tourists and Irish every year. The proposed plan by Saorgas Energy Ltd could only have a baleful effect on the stream of tourists into the area, thus endangering the jobs of many people who depend on these tourists for their livelihood.

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Ireland has been led into economic ruin. I urge you to withdraw the proposal that will lead the country into aesthetic ruin. Submission No. 129 The Minister for Environment, Community & Local Government Department of Environment, Community & Local Government, Marine Planning & Foreshore, Newtown Road, Wexford Co Wexford Dear Minister, I wish to object to the granting of the above leases on the following grounds:- 1.There would be significant adverse visual impact on protected and preserved views and prospects which are listed for protection in local area development plans in Dun Laoghaire Rathdown and Wicklow. The development would cover an area of 54km2 and would be visible from North Dublin to Wicklow. It would have the potential to impact on eighteen sites designated or candidates for designation as Special Areas of Conservation or Special Protection Areas. 2. The expected adverse impacts on the Dublin Bay Natura 2000 site are detailed in the submission on behalf of the Irish Whale and Dolphin Group. The Group is dedicated to the conservation and better understanding of whales, dolphins and porpoise in Irish waters. 3. The assertions re job creation and value for money are vague unsubstantiated and inadequate. 4. Misleading information is presented with regard to the electricity which would be generated. Dublin Array state (RDS display) that "when fully operational, the wind farm will be capable of generating at least 520MW of clean energy". On average wind turbines generate between 15% and 30% of their maximum capacity. For example, a 3MW turbine generates less than 1MW. It may be true that “the wind farm will be capable of” generating X amount of energy, but in the real world this will never happen. The wind doesn’t always blow. When it does blow it doesn’t always blow at the optimum speed. It is generally accepted that approximately one third of maximum capacity is actually generated. 5. The Irish east coast landscape would be sacrificed, in order to provide energy to the UK. 6. Ireland has no proper up to date system of planning for foreshore leases. As is stated by the Coastal Concern Group, a proper democratic planning framework must be put in place to protect our precious and coasts and seas. I strongly support this. The Minister is charged with the responsibility for granting or refusing leases on behalf of the public and is required to make the decision “in the public interest”. I do not believe that it is in the public interest to grant the foreshore leases in this instance.

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Submission No. 130 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) Please read below SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland:

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○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the

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effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am

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confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is

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extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 131 Dear Sir/Madam, I wish to object to the granting of the above lease. I support the submissions made by Wicklow Tourism, The Irish Whale & Dolphin Group, Coastal Concern Alliance, and the Sandycove & Glasthule Residents Association. In addition, however, I wish to emphasise a number of points. 1.The Visual Impact of this development is utterly unacceptable on one of the most beautiful sections of the east coast. I get peace and solace from the many stunning seascapes around Dublin bay and off the east coast, regardless of whether it's flat calm or blowing a gale.

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2. In the developer's EIS I see no assessment of the environmental impact on Material Assets. This is required under the EIA Directive and SI No. 433 of 2012, European Union (Environmental Impact Assessment) (Foreshore) Regulations 2012, 3(c). 3. I am seriously concerned about the very poor quality of the data presented in the EIS. 3a. Firstly, the failure to adequately address the very significant disturbance to protected sandbanks which would inevitably result from the drilling of foundations (probably mono pile) in this vulnerable near shore environment. The EIS states (4.4.4) "The wind farm would not destabilise the banks or have a negative impact on the coastline". It is astounding that such a statement can be made without a shred of evidence to support it. The EIS is supposed to provide reliable evidence-based information, not vague unsubstantiated statements. 3b. Secondly, the Natura Impact Statement in relation to the cSAC and the designated species, the Harbour Porpoise. The EIS suggests that to mitigate any threat to the porpoise, Marine Mammal Observers would be put in place. The Irish Whale and Dolphin Group clarify that Harbour Porpoise are difficult to detect, even using trained observers, and that they cannot be seen unless the sea state is 2 or less. Neither can they be observed unless there is adequate light. Is it really credible that such a major development could progress within the limitations imposed by such rigid mitigation criteria? I do not think so. 3c. Thirdly, the fact that it is stated that, probably one, electricity substation would be constructed on the banks. There is virtually no information with regard to the environmental impact of this substation. This is a very significant omission. We are told (2.3.5.2): "As noted above the wind turbines of The Dublin Array will transmit power along relatively low voltage array cables to an offshore substation where the voltage will be increased for transmission along a higher voltage export cable to the shore for connection to the national grid. It is envisaged that a single offshore substation will be used to transform the power from the turbine circuits to the higher voltage suitable for export to the National Grid. The proposed substation will be located towards the centre of the array and is likely to be supported on a multipile foundation structure given its size. A typical offshore substation is illustrated in Figure 2.6." A photograph of a substation is included! What can we learn from a photograph? We are also told the substation will be 40 metres high and that among 145, 160 metre high turbines, the visual impact will be "insignificant". While I am in agreement with the latter, the fact the substation is located in the middle of a massive offshore development does not mean that it can be omitted from the environmental impact assessment process. No information is given about the presence (or absence) of an electromagnetic field in the vicinity of the substation, nor about the damage to the banks which would result from drilling numerous pile foundations in close proximity to each other. How many piles would there be and over what area? I consider the lack of information here to be totally unacceptable. I also looked at the photomontages supplied with the EIS and could not see any representation of the substation. It should be included.

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I trust that you will give my objections serious consideration and refuse this lease application. Submission No. 132 Please note my objection to this project. Submission No. 133 Re Proposed lease for Wind Farms Ref MS 53 /55/L1 - Developers: Dublin Array Attention: Minister P. Hogan Department of the Environment, Community and Local Government Objection Please accept this communique as a formal objection to the granting of a Lease re the above private development. Whilst this objection is made on behalf of many persons of similar strong viewpoint with who I have consulted on this matter, it is also made in support of the more comprehensive objection lodged with your office from the focus group, Coastal Concern Alliance. An expression of our own particular issues on the subject (objection) is summarised as follows: Visual Impact The significant adverse visual impact on protected views and prospects which are listed for protection in local area development plans in Dun Laoghaire Rathdown and Wicklow. The developer's commissioned study that sets out an Environment Impact Statement (EIS), describes the adverse visual impacts. This is reinforced and expanded upon by the independent professional assessment submitted to you on behalf of Coastal Concern Alliance, which categorises all visual impacts to be significant, profound and negative. Job Creation The vague unsubstantiated assertions re job creation and value for money. It would be reasonable to expect that Dublin Array would apply some of the conventional criteria well enunciated by IDA and Enterprise Ireland as to the ratio of jobs generated versus level of inward investment. They assert that sustainable employment will be generated by the contemplated investment of circa. €1,500,000,000. It would be helpful if details of employment levels generated (i) during construction and (ii) sustained post commissioning, could be demonstrated convincingly. The dearth of information currently provided makes this impossible. Renewal Energy for Ireland It is suggested that two possible customers could avail of the intended power generated, the Irish energy grid or the UK/EU grid. In this context it must be clarified that this is a development proposal by a private developer, not by the Irish state. If the generated energy was to be exported there is no indication that there would be any accruing benefit to Ireland, its citizens, taxpayer or government

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coffers. Might this simply be an EU part-funded scheme that is using (exploiting) the Irish scenic foreshore to feed the EU industrial/power needs without ANY real benefits flowing to Ireland? Economic Benefit and/or Financial Benefit Nowhere is there an attempt to explain the difference between (i) the economic benefit and (ii) the financial benefit accruing form the proposed development. Clearly the promoters have satisfied themselves on the financial (investment) return that will accrue to them. But there is no expression as to the economic benefit to the people of Ireland, if any. Conclusion This proposed project demonstrates little economic benefit to Ireland and plays vaguely on "green" and "renewable" energy concepts that are gratuitous and present utterly misleading impressions. I therefore urge refusal of the lease application. Submission No. 135 SAVE OUR SEAFRONT SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT RE PROPOSED DUBLIN ARRAY PROJECT ON KISH BANK (MS53/55/L1) Introduction Save Our Seafront is a community organisation based in Dun Laoghaire. It was established in 2002 and has campaigned on a number of issues including the proposal in 2012 to allow drilling for oil in Dublin Bay. Save Our Seafront is in favour of renewable energies. We welcome effective policies and plans that will see Ireland transfer some of its energy sources from fossil fuels to renewables and work towards reaching targets for renewables set by the EU. The world’s reliance on fossil fuels is unsustainable. Ireland is 80% reliant on fossil fuels, it needs to reduce this to 60% at a minimum by 2020 and ideally exceed this target. We are currently, according to the Minister for Energy, 630 MW behind where we should be. In order to achieve this we need an effective national plan for renewable energy, that is state led, open to public scrutiny, respects the natural environment and has a built in process of consultation and appeal in line with best practice. The proposal for a wind farm on the Kish Bank on the surface looks like a step in the right direction, provided that it is managed to maximise both the renewable energy and financial return to the state. However, we have some major concerns that we would like to be addressed before any decision is made to grant approval for the Saorgus project. Foreshore Act The Dublin Array project is subject to the Minister for the Environment granting a Foreshore Lease to install the 145 wind turbines just 10 km from the coast. The Foreshore Act 1933 is the legislation that governs the granting or refusal of this lease. This raises a number of issues about which we are concerned:

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The Act provides minimal opportunity for public consultation and lacks transparency. There is no involvement of a planning authority, whether Local Authorities or An Bord Pleanala, in the granting of Foreshore Licences/Leases. The absence of any appeal procedure is not in line with best practice when it comes to decisions that affect the environment. The Department of the Environment has already acknowledged that the Foreshore Act is outdated when it opened up a public consultation process on a new Foreshore and Marine Area Development Bill. The Aarhus Convention, which Ireland ratified in June 2012, aims to increase public involvement in all matters relating to the environment. Its provisions are broken down into three pillars – Access to information, Public participation in environmental decision making and Access to justice. The lack of any appeals procedure surrounding the granting or refusal of a Foreshore Licence/Lease begs the question as to whether there is real access to justice for people with concerns around a particular foreshore application and whether the Foreshore Act 1933 meets the requirements of the Aarhus Convention. Considering the above we ask you not to grant the Foreshore lease for this particular project until we can be sure that the process is in line with EU requirements and the public are offered the full provisions recommended in the Aarhus Convention. A plan for renewable energies and protection of our natural resources In Save Our Seafront we believe that a coherent plan for renewable energies must be state led and part of a strategic plan to develop alternatives to fossil fuels. The state owned company ESB is best placed to implement this plan as its core objective is to provide for the energy needs of the state. Where private companies put forward proposals to build energy infrastructure or develop alternative energy sources; the state should identify the prime sites for development and hold a public tendering process to ensure that development is in the public interest and that it has an adequate return to the state taking into account all the relevant factors including the financial and environmental costs The Kish Bank was selected, according to the proposers of the project, because it “had all the attributes ideally required for an offshore wind farm - high wind resource, suitable water depths and ground conditions for installation of turbines, proximity to the high electricity demand of Dublin, lack of interference with shipping or fisheries etc.”. If this is the case, it means that the Kish Bank is a valuable Natural Resource and as such should be protected and only exploited in the interests of the Irish people. The tax, royalty and licensing arrangements for development of wind energy need to have clear benefits for the Irish people. Considering the controversy that has surrounded this in relation to Oil and Gas exploration the public need specific details and guarantees of the benefits before any lease is granted. There are also question marks over the cost benefit of wind energy that needs to be addressed. David McKay’s research “Sustainable Energy Without the Hot Air” suggests that the energy returns are questionable. A number of other reports question the real cost per unit of electricity compared to other forms of generation. While we understand that the development of renewable energies is of benefit to all the people of the world, the development in our own country should be of specific benefit to the Irish state in

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terms of reaching the EU targets for 2020, guaranteeing a security of supply of energy and providing a revenue stream that can play a part in emerging from the current economic crisis. In the government’s ‘Strategy for Renewable Energy 2012 - 2020’ document it states ‘Our offshore wind resource will be developed as an export opportunity to UK and North West Europe’. As this is the only reference to wind energy development in the entire document it strongly indicates that the intention is to export the energy and not supply the Irish in order to help us reach our 2020 targets. Any renewable energy project located in Ireland should be used to guarantee energy supply in Ireland and achieve our targets for renewable energy before supplying any foreign markets such as the UK. The Foreshore Act states: “Foreshore Leases may be assigned with the agreement of the Minister but consideration will not normally be given to any such assignment during the period of application, construction or initial 2 year period of generation of electricity.” This clause is clearly there to guard against speculation. Despite this clause the valuable 99 year leases given for the Arklow and Codling Banks to Irish promoters were sold on in 2008 to international power companies. The price was based on the size of the permitted development. The application for the development of Dublin Array is from a small Kerry based company called Saorgus. We are concerned that the licence to build and operate the Kish Bank wind farm, once the necessary leases are secured, will then be sold on to a third party. In such a case, what guarantees will be provided that the output, control, and economic and environmental benefits accrue to the state rather than some multinational investment company? Size of installation and proximity to land The applicant is looking for a lease to install 145 turbines just 10 km from the coast of Dublin. There is only one wind farm currently operating in the world that is bigger than this – London Array which has 175 turbines. The planned farm is just 10kms from the coastline. Across Europe a best practice buffer zone of 22kms is developing. Already this buffer zone is in place in Germany, Belgium and The Netherlands. A similar buffer zone has been recommended in Denmark and in the UK. Dublin Bay and the Wicklow coastline are vital to our heritage. Its natural beauty and its literary associations play an important role in tourism on the east coast. While we understand that the development of renewable energies will change and impact on our land and seascapes, we believe that the sheer size and proximity of this development would mean the industrialisation of Dublin Bay and Wicklow Coast. We also have concerns about the technical competence of Saorgus. Nothing in their application indicates any previous experience in executing a project of this size. The Department of the Environment and Department of Communications state that they are undertaking a targeted review of The ‘Best Practice Wind Energy Guidelines’ published in 2006, to address the manner in which guidelines affect key issues of community concern to ensure wind energy does not have a negative impact on local communities. The 2012 government policy statement on strategic importance of transmission of other energy infrastructure emphasises the importance of local community acceptance and adherence to national and international best practice.

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The Department also states that the Saorgus application will not be assessed until the offshore renewable energy development plan OREDP has been published. When the application is assessed it will take into account associated SEI. Given the above, what specific steps are the government taking to ensure local community acceptance and adherence to international best practice. Will the government ensure that all information in relation to this project is provided to the local community and their concerns will be taken into consideration before any decision is made on the project. Environment The shallow sandbanks along our coast are an important breeding and foraging ground for many marine species. Of particular concern are the Harbour Porpoises protected under the adjacent Rockabill to Dalkey Island Area of Special Conservation (SPA 004014). The government is required under the EU Habitats Directive to ensure conservation measures are in place to appropriately manage the SAC and ensure appropriate assessment of plans and projects likely to have a significant effect on the integrity of the SAC. It seems likely that the proximity of the project to this SAC will have an effect on its integrity. Also of concern are the Purple Sandpiper and Tern colonies likewise protected under the EU Habitats Directive. The installation of 145 turbines could potentially seriously damage these sandbanks and disturb the habitats of these protected species. Exclusion zone – effects on water sports and leisure – tourism According to the European Wind Energy Association the locations of existing and planned offshore wind projects in the EU tend to be geographically separate from areas of high coastal tourist use. This is a factor in the development of a 22 km buffer zone use by several countries. A number of studies have been done on the visual impact on amenities available to both the local community and the tourist industry. Jacob Ladenburg and Sanja Lutzeyer have suggested that from “a welfare economic point of view there is a non-trivial economic trade-off between offshore generation costs and the visual impacts from offshore wind farms. Offshore wind farms close to the shore generate cheaper electricity, but also cause higher levels of visual impacts compared to locations at larger distances”. They go on to outline the problems associated with such installations close to the shoreline. While many of the American studies concentrate on the trade-off between the visual impact, the financial benefits provided to the local community to compensate for the visual loss of amenity versus the environmental benefits to society as a whole; they all stress the importance of openness, engagement with the local community, a democratic process that involves the local community in an attempt to balance all the various concerns and interests. The coastal area from Dun Laoghaire to Wicklow is a huge tourist attraction and the visual impact on this is of major concern, particularly the cliff walk from Bray to Greystones This has not been the case with the Kish Bank proposal. We believe that the licence should not be provided until such a process has taken place. Summary Save Our Seafront are in favour of any move toward renewable energies, in order to meet targets set for 2020. However, EU directives and international best practice need to be observed. The Danish, who could be considered leaders in this field produce 30% of their electricity through wind

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energy, a figure which they have pledged to increase to 50% by 2020. In 1999 they passed a bill ensuring that the right to exploit energy from wind and water within their territorial waters and economic zone belongs to the Danish government. Tendering is common practice in the pre – exploitation phase to ensure competitiveness and a public appeals process is in place in line with EU law. They have recently moved toward introducing a buffer zone of 22 km and they have produced extensive studies on near shore and off shore wind projects. It would make sense for the government to consult with other countries such as Denmark to produce a comprehensive marine spatial planning strategy. In consideration of the above concerns we ask that no decision be made on a possible wind farm on the Kish Bank until all of them are addressed. Submission No. 136 I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) Submission No. 137 The Department of the Environment, Community and Local Government, Marine Planning and Foreshore, Newtown Road, Wexford. I have only heard about the proposal by Saorgas Energy Ltd to erect a wind farm on the Kish Bank and Killiney Bay and I wish to lodge an objection to the undertaking. Killiney Bay is recognised as one of the top beauty spots in the entire Country and compares favourably with other well-known beauty spots not only on Europe but world-wide as well. Such a development would be very detrimental to the wonderfull aspect from Killiney Hill around to Bray Head. I sincerely hope permission will be withheld. Submission No. 138 Red: MS53/55/L1 Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Co. Wexford Dear Sir/Madam, I am writing to express concern about the visual impact that this sized project might have on the Dublin coastline. While I am a supporter of renewable energy, there is considerable concern locally about the visual impact that the proposed number of wind turbines might have on our coastline. I would ask that you take this and other similar observations into account when making your decision. Yours sincerely,

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Cormac Devlin Councillor Cormac Devlin Fianna Fáil County Councillor for Dun Laoghaire Office:(01) 275 0786 Email: [email protected] Website: www.cormacdevlin.ie Facebook: http://www.facebook.com/Cormac.devlin Twitter: http://twitter.com/cormac_devlin Submission No. 139 To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] Dear Madam/Sir. I refer to the Dublin Array Application for Foreshore lease. I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) As a member of Dublin Bay Concern I note that we recently supported Minister Jimmy Deenihans¹ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Therefore, I wish to register my objection to the proposed establishment of wind turbines until clarification is obtained in regard to Foreshore licence procedures and the effect of pollution caused by the Dublin Array Application for a Foreshore lease. This clarification must be transparent and also consultation on this subject must include members of the various groups who oppose this project for many reasons, not least of which is the secretive decision-making procedures which we fear may be decided without our knowledge, consent, or even, participation. Submission No. 140 Re: Application for Foreshore Leases, Ref: MS53/55/L1 Dear Minister Hogan, I wish to object to the granting of the above leases on the following grounds;- 1. There would be significant adverse visual impact on protected and preserved views and prospects which are listed for protection in local area development plans in Dun Laoghaire/Rathdown and Wicklow. The development would cover an area of 54Km2 and would be visible from North Dublin to Wicklow. It would have the potential to impact on eighteen sites designated or candidates for sedignationa s Special Areas of Conservation or Special Protection Areas.

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2. The expected adverse impacts on the Dublin Bay Natura 2000 site are details in the submission on behalf of the Irish Whale and Dolphin Group. The Group is dedicated to the conservation and better understanding of whales, dolphins and porpoise in Irish waters. 3. The assertions re job creation and value for money and vague, unsubstantiated and inadequate. 4. Misleading information is presented with regard to the electricity which would be generated. Dublin Array state (RDS Display) that "when fully operational, the wind farm will be capable of generating at least 520MW of clean energy". On average wind turbines generate between 15% and 30% of their maximum capacity. For example, a 3MW turbine generates less than 1MW. It may be true that " the wind farm will be capable of" generating X amount of energy but in the real world this will never happen. The wind does not always blow, when it does blow, it does not always blow at the optimum speed. It is generally accepted that approximately one third of maximum capacity is actually generated. 5. The Irish east coast landscape would be sacrificed, in order to provide energy to the UK. 6. Ireland has no proper up to date system of planning for foreshore leases. As stated by the Coastal Concern Group, a proper democratic planning framework must be put in place to protect our precious coasts and seas. I strongly support this. The Minister is charged with the responsibility for granting or refusing leases on behalf of the public and is required to make that decision "in the public interest". I do not believe that this is in the public interest to the foreshore leases in this instance. Submission No. 141 To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory

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well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive.

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Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”.

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There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://www.dublinbayconcern.ie/component/acymailing/url/subid-1154/urlid-19/mailid-28?no_html=1http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of

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tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinbayconcern.ie/component/acymailing/url/subid-1154/urlid-21/mailid-28?no_html=1http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal

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would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 142 I am contacting you to object in the strongest possible terms to the above lease application for the construction of a large scale wind-farm ('Dublin Array') along the south county Dublin and Wicklow coastline. There is no doubt that this proposed industrialisation of the seascape will have a hugely negative effect on tourism to the area; as well as on the enjoyment of residents of Dublin and Wicklow. In fact, the Vico Road stretch of coastline will cease to be the beauty spot that has so often been compared to the Bay of Naples. I cannot believe that such a lease application is even being considered; and I consider it a disgrace that, due to outdated legislation, it can be introduced in such an underhand manner. It is only by pure chance - a chance encounter with a concerned fellow-resident - that I heard about this possibility of the destruction of one of the most beautiful areas our country has to offer. And all this is before even mentioning the negative environmental impacts. Once again, I object to the construction of the above wind-farm in the strongest possible terms. I would appreciate if you could acknowledge receipt of this email, which is being sent before the expiry of the time limit for submissions. Submission No. 143 To whom it may concern, I would like to lodge a submission in SUPPORT of the proposed off shore Wind farm development proposed by Saorgus Energy Ltd on the Kish and Bray banks. This development has the potential to create substantial quality employment for the area at a time when local employment is scarce and national unemployment is at unsustainable levels. The opportunity to generate over 500 MW of clean electricity from such a sustainable source is simply an opportunity this county cannot afford to delay. This development is approximately 10km off shore, that’s not exactly in your face. In reality these turbines will be so far offshore that they will hardly be seen at all. I live in Wicklow Town and just off shore between here and Arklow are the six turbines of the Arklow Banks Windfarm. These are of a similar size and at a similar distance out to sea. The problem with visibility is that when friends come down and want to see the turbines they usually hidden in mist or fog; hardly visible to the naked eye. A conventional on-land power generating station would have considerable more visual and environmental impact than this project.

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The tourist potential of this development has to be quite considerable judging by the number of friends and acquaintances who have come here to see the Arklow Banks Wind farm. A development of this size would create the opportunity for boat tours etc. We are employers in the local area with three companies and we regularly see good people looking for and wanting to work; in the current situation there is little or no opportunity for them locally, leaving emigration as the only option. 250 full time jobs and an investment of 2 Billion is simply too important not to support in every way possible. One of the unseen benefits of Offshore Wind farms is their ability to create a safe haven for fish to breed and develop away from the big trawlers. I am told by my rod fishermen friends that the improvement in both numbers and varieties of fish found around the six turbines here is incredible in the last few years. Again the Tourist potential for fishing tours and international competitions is huge, the spinoff for Hotels and B & B’s and the entertainment business in general is very significant. Furthermore as this wind farm will be the largest in Europe it could be turned into a tourist attraction with tours, visitor centre, shops and restaurants! To develop a Wind farm on land of this scale would have a far greater impact visually and physically. As a country we need to be responsible as to how we supply the energy we need. With much of our generation capacity needing to be modernised or replaced a clean energy development of this scale seems to me to be essential. The advantages of this project far outweigh any perceived concerns; we have to be more responsible in how we generate our electrical needs and indeed how we use them. I would just like to point out that neither I nor any of my family or friends has any connection with the promoting company or have any knowledge of the people behind the company. We also have no Tourist, Entertainment or nautical interests either. Submission No. 144 SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) I am a private individual writing to advise you that I am not if favour of the Irish State issuing a foreshore lease for the construction of the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) I am in favour of the development of renewable energy as a necessary alternative to the continued use of non-renewable fossil fuels but I am not in favour of this particular proposal as I believe it represents massive overdevelopment far too close to an environmentally sensitive and somewhat unique coastline. In addition I believe it will generate none or minimal benefit for Irish citizens in return for destroying a unique amenity which has been cared for and protected at significant public expenditure up to now. Public Consultation and Transparency The Foreshore Act 1933 is the legislation that governs the granting or refusal of this proposed lease. This raises a number of issues about which I am concerned:

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The Foreshore Act provides –

(A) Totally inadequate opportunity for public consultation and lacks the degree of transparency that would be appropriate to a development of the scale proposed.

(B) There is no involvement of a planning authority in the granting of Foreshore Licences/Leases.

(C) The absence of any appeal procedure is completely wrong when it comes to decisions that affect the environment on such a massive scale as this proposed project.

(D) The Department of the Environment has already acknowledged that the Foreshore Act is outdated when it opened up a public consultation process on a new Foreshore and Marine Area Development Bill.

The Aarhus Convention, to which Ireland signed up in June 2012, promotes public involvement in all matters relating to the environment and its provisions are under three main headings – Access to information – Public participation in environmental decision making – Access to justice - The lack of any appeals procedure surrounding the granting or refusal of a Foreshore Licence/Lease under the 1933 foreshore act means there is no real access to justice for people with concerns about a particular foreshore application. The Foreshore Act 1933 does not meet the requirements of the Aarhus Convention. Considering the above there should be no granting of a Foreshore licence for this particular project. Irish State control and development of Irish Resources for the benefit of Irish Citizens. I believe that a coherent plan for renewable energies involving the use of Irish resources must be state led. The state should be identifying prime suitable sites for development and if a situation arises where it is considered appropriate that private participation in projects should be invited, then this should only happen by way of a transparent public tendering process to ensure that any use of Irish resources is in the best interest of Irish citizens. The Kish Bank was selected for this proposed development because according to the proposers of the project it “has all the attributes ideally required for an offshore wind farm - high wind resource, suitable water depths and ground conditions for installation of turbines, proximity to the high electricity demand of Dublin, (i.e- easy connection to an existing grid) lack of interference with shipping or fisheries etc.” Indeed if this is the case, it means that the applicant sees the Kish bank as a valuable Public site on which they hope to economically construct a wind energy project for the purposes of private gain. The tax, royalty and licensing arrangements currently in place for the development of wind energy are such that the Irish state and the Irish people are not the beneficiaries and under these outdated arrangements no further licences or leases should be granted until such time that we are sure that the use of Irish resources is only allowed where the Irish public can be sure the Irish state derives maximum benefit from allowing their use.

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When the Foreshore Act was created in 1933 the Kish Bank was no more than a shipping hazard and offshore wind energy was unheard of. Circumstances have changed and the 1933 act it totally inadequate for dealing with proposals such as this. Speculation / Assignment of Lease The Foreshore Act states: “Foreshore Leases may be assigned with the agreement of the Minister but consideration will not normally be given to any such assignment during the period of application, construction or initial 2 year period of generation of electricity.” - a clause that presumably was drafted to guard against speculation. Despite this clause the valuable 99 year leases given for the Arklow and Codling Banks to Irish promoters were sold on in 2008 to international power companies. The price was based on the size of the permitted development. The application for the development of “Dublin Array” is from a small Kerry based company called Saorgus. I am concerned that a lease for the use of this Irish resource if it is granted will then be sold on to a third party at a price associated with the permitted development. Indeed I see no evidence of this small Kerry based group who are proposing to develop the second largest such project in the World, having any technical experience of previously having completed offshore wind energy projects. Appropriateness of 145 large turbines just 6 miles offshore in Dublin Bay The applicant seeks a lease to install 145 turbines just 6 miles/10 km from the coast of Dublin. There is only one wind farm currently operating in the world that is bigger than this – London Array which has 175 turbines. Across Europe a best practice buffer zone of 22kms is developing. Already this buffer zone is in place in Germany, Belgium and The Netherlands. A similar buffer zone has been recommended in Denmark and in the UK. Dublin Bay and the Wicklow coastline are vital to our heritage. Its natural beauty and its literary associations play an important role in tourism on the east coast. While I understand that the development of renewable energies may inevitably have some impact on our land and seascapes, I believe that the sheer size and proximity of this proposed development is inappropriate. The visual impact of these enormous turbines cannot be understated. Ireland is famous worldwide for the beauty of its coastlines and to consider blotting our unique Dublin Bay with these huge 160 metre high turbines that will deliver no economic or environmental benefit to Irish citizens is beyond comprehension. The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and the impact of the industrialization of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits, but has no data to support these statements. It is clear that electricity generated from this proposed array would be primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to

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utilize the vast majority of energy generated by this array .To my knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore to the detriment of Irish citizens. Tendering As with all Irish state assets this site should be subject to the principles contained in the Irish Government's own guidelines regarding disposal of State assets or the granting of access to them. The Irish Government guidelines for the Governance of State bodies set out a requirement to sell, or award and access concession only following an auction or competitive tendering process and this same principle should apply in cases such as this. There is no evidence of any such tendering or auction process having been conducted in relation to the granting of a 99 year lease for the use of this particular state asset and this and all other licences, leases, concessions or permits involving the use of Irish resources should at the very least be subject to competitive tendering via clear and transparent notices advertised on the European Union Tendering Journal. Wildlife There is insufficient data as to the extent to which a development of the sort proposed would affect the wildlife in what is a special area of conservation, and I would have serious concerns about probable damage to flocks of migratory and resident sea birds. For all the above reasons I submit that this application should be refused. Submission No. 145 Wicklow Enterprise Park The Murough Wicklow Tel: 0404 66433 Fax: 0404 66464 Email: [email protected] Web: www.wicklowchamber.ie Submission on behalf of Wicklow Town and District Chamber of Commerce. To Whom it may concern, We wish to present a submission on the proposed off shore Wind farm development proposed by Saorgus Energy Ltd on the Kish and Bray banks. Our submission is made in support of this project. It is the Chamber’s view that this project should receive the utmost support and encouragement in order to make it a reality as soon as possible. The potential to generate over 500 MW of clean

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electricity from a sustainable source offshore, with limited environmental or visual impact and the probability of creating 600 construction and 250 well paid, permanent, full time jobs is an opportunity we should be encouraging. In addition there the financial and economic spin off which will have such a dramatic benefit for local business and families must be taken into consideration. Opportunities of this quality are very rare at any time and especially so in the current climate. This development is approximately 10km to 14km off shore and as such means it will have a very limited impact visually. This development will be so far offshore that the turbines will hardly be seen at all as is evident by the Arklow Banks Wind farm adjacent to the town. These are of a similar size and at a similar distance out to sea. The turbines are only faintly visible to the naked eye on a good sunny day and are often shrouded in mist or fog. Their presence is not considered to be unacceptable to most observers and we suggest that the environmental impact and visual appearance of a conventional power station would have many times the impact of this project. The reality is that we need more electricity and it must be generated in a sustainable manner. The question then arises as to where this power will come from. This project will provide a sustainable source of electricity well into the future in addition to providing employment and related commercial activity for decades to come. This development has the potential to create substantial quality employment for the area at a time when local employment is scarce and national unemployment is at unsustainable levels. It is our opinion, that this development has considerable Tourist potential, as is evident by the number of boat trips available on the internet to other large wind farms around the world. It would certainly generate more visits to Wicklow and surrounding counties as a result of activities designed to support such an initiative. This is only the beginning. The spin off to the local hospitality industry will be significant and we believe this should be seen as a very positive development. Submission No. 146 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1)

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SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) I am once again very disappointed that plans have been made to put an inappropriate Structure in the bay. Once again without the correct research on the long-term environmental , cultural , economic and social effects . This Wind Farm yet again , as in the case of the proposed rig , appears to have little or no benefit to the Irish citizen and is a for Private profit venture at our expense . I would not have had wind , excuse the pun , of it had I not been on a mailing list as a result of opposing the granting of Providence License . I am at a loss as to why we have to keep fighting to protect our beautiful bay from the hands of profiteers without consultation or research or potential , if not sort sighted , gain to us as citizens. I am personally opposed on the grounds of it ruining the bay for citizens and visitors, wildlife and the future environment for our children . Lack of transparent and reliable research. Lack of adequate public consultation. Lack of benefit to the citizens of Ireland. Potential loss to fisherman and small aquatic based business in the bay. Submission No. 147 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence,

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Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive.

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Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”.

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There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of

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tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal

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would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 148 Sir/Madam Having perused the Environmental Impact Statement and examined the Photo Montages and read all available accompanying communications available to us in the public domain and on display in the Public Libraries we have no hesitation in herewith lodging our objection to the above application on the following grounds: 1.the project is an exciting useful and highly profitable for the Promoters but it fails utterly on one basis IT IS IN TOTALLY THE WRONG LOCATION 2.The gross size and scale of the proposed development is both excessive and extreme. It is proposed as being 17KM long comprising of 145 turbines with a height of 160m. 3.The proposed development in this LOCATION will have a significant and Massively negative impact on the shoreline views of many thousands of residents and visitors to this recognized world acclaimed areas of outstanding natural beauty extending from Dun Laoghaire to Bray Head to Greystones and Howth. 4.The Land and Seascape shall be industrialised for all time to the detriment of the culture beauty and heritage of the area, instead of a vibrant colourful Marine outlook generations would inherit a bleak unnatural industrial man made growth in the middle of the sea. 5.According to RTE technical team interference shall occur to many thousands who receive overseas TV channels which reception is likely to be adversely affected by proposed installation. 6.There shall be degradation of the protected sea banks with knock on effects resulting in coastal erosion. 7.There shall be long term adverse effects on marine and wild life birds etc. 8 We are advised that the granting of any such license would be in breach of EU environmental legislation and we would exercise our right to pursue the overturn of any grant of a Licence in all Courts as appropriate. 9.As an experienced seaman with extensive knowledge of the subject waters this project represents a clear danger to Mariners in many respects which i shall expand on where required to so do.

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Essentially it is a Project which looks great on paper in many respects but it is simply PROPOSED FOR THE WRONG HIGHLY DENSLEY POPULATED AREA. Submission No. 149 Please find our submission in support of the Saorgus energy application for foreshore licence. To whom it Concerns. We wish to make a submission in support of the foreshore application which has been made by Saorgus Energy. We believe the license sought should be granted by the department in the economic interest of this state and its inhabitants. The argument against the project on the basis of its possible appearance is weak compared to the socio economic benefit which is likely to be achieved if the project is successful. It is suggested that various professional studies and assessments have already taken this into account and have addressed the issues relating to the presence of turbines in this area. The visual impact created by such a wind farm would be minimal given the distance offshore and there are many examples of successfully operated and managed facilities both on and offshore. Opinion on visual appearance is very much a subjective matter. Considerable investment has taken place in many countries on the European seaboard. Presumably all of these developments have been properly assessed and evaluated in line with EU requirements prior to construction. This suggests there is reasonable precedent for granting the licence. There is very considerable potential for employment during the construction phase in addition to the prospect of substantial additional direct and indirect employment for many years to come. We trust you will take the many 'positives' into consideration and will conclude that the granting of the licence is the correct course of action. Submission No. 150 To whom it concerns, I have just heard about the plan to put up windmills in Killiney bay. Much as I appreciate the idea of wind mills, I feel that Killiney Bay is not the ideal place. Surely there are less beautiful places where the windmills could be erected. It seems a pity to change the view of Killiney Bay. Submission No. 151 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation

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Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%.

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These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of

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energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies."

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http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness

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amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application Submission No. 152 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] Dear Sir / Madam, I am writing as a private individual to express in the strongest terms possible my concerns as to how our natural resources including Wind are being managed. Below the team at Dublin Bay Concern have highlighted many of the immediate flaws in this thinking, I fully support their document, and the submission from others like the Coastal Concern Alliance. It is hard to know where to start to object to a proposal such as this, maybe I should firstly say in principle I am in favour of green energy, but absolutely 100% not in the form and shape of this

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proposed project. The Dublin Bay Concern submission below makes a series of points which I fully endorse, however I would also like to make a few additional points. I would like to make this analogy, in effect..... We are offering a parcel of land (i.e. under the sea) to a developer, we are offering the land for free and we are asking the developer how big a development would they like to build. We have absolutely no planning requirements. Tthe developer can build as large a development as he likes. As with all developers faced with the prospect of building with no restrictions, and with no concerns about revenue return on his development, he will simply build all the way to the sky, the motto being the bigger the better, and why not the bigger the more money he makes. To cap that off, our government are happy with a few jobs and a promise of tax down the road. It is completely unacceptable that we the people have absolutely no ownership of any of the energy generated, it is in the hands of a private company, and once again our government will rely only on tax. Tax I believe will be minimal, and when the inevitable happens and an international company eventually buy the licence from Dublin Array as usually happens with these types of projects, the new owners international tax experts will ensure the tax payable to Ireland will be minimal. This approach, a jobs and purely tax based model in my opinion simply doesn’t work when it comes to our natural resources, it might be seen to work in other industries with other forms of direct investment, i.e. pharmaceuticals , software etc. These are real skilled jobs, there is no take from the land, with very little downside, this is completely different in the case of off shore wind / oil or gas. I firmly believe the energy is destine for the UK and why because the UK are not prepared to have massive industrial scale wind farms in their own bays, why might that be I wonder. I am all for wind energy and all for those involved to make a reasonable profit, but only when the playing field is level, the process is transparent and the competition is fair. We have a single private company setting the agenda here, deciding the terms, choosing the location for the site, deciding the scale of development, and basically helping themselves to our resources. The company have played a cleaver game by not publishing visual and photo montages of the development, but rather have come up with a story that the visuals are not suited for publishing on their website, incredible is the only work for this. They have created what I believe to be artificial full 180 degree panoramic views to make the development appear less industrial. No human eye can view 180 degrees, we can only see pretty much directly in front of us, but not 180 degrees. I see this lack of transparency and attempt to create a false impression as very worrying. How insulting all this is, the people of Ireland are sick and tired of clever corporates trying to get the one over on them, we have learnt hard lesson over the last 5 years and the Celtic era.. This style of doing business has no place in a country trying to recover only projects that have a genuinely positive contribution to Ireland Inc. are worthy. If as a country we decide on wind energy (be it Dublin Bay, Galway Bay or any bay in the country) is the way forward, I am all for that, but show me the financial model so that we the people of Ireland benefit. Snow me the tender process to select the best company to run the operation, to build in the case of Dublin Bay one of the biggest Wind Turbine Farms in the world. Show me the plans, the drawings, the real visual images, don’t try and hide them in four dusty libraries dotted around Dublin, so that most people will not see them. Show me a council approved planning process to ensure a scheme is in keeping with the environment its located. We will only have one chance to either protect, or potentially destroy Dublin Bay. We must make sure we do this wisely or not at all.

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Needless to say I reject this proposed development by Dublin Array on these grounds, and the ones detailed below. SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation.

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Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info <http://www.dublinbayconcern.ie/component/acymailing/url/subid-813/urlid-18/mailid-28?no_html=1> ) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of


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energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of &euro3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies."

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<http://www.dublinbayconcern.ie/component/acymailing/url/subid-813/urlid-19/mailid-28?no_html=1> http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2 <http://www.dublinbayconcern.ie/component/acymailing/url/subid-813/urlid-20/mailid-28?no_html=1> ) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements <http://www.dublinbayconcern.ie/component/acymailing/url/subid-813/urlid-21/mailid-28?no_html=1> http://www.dublinarray.com/benefits.html <http://www.dublinbayconcern.ie/component/acymailing/url/subid-813/urlid-21/mailid-28?no_html=1> . It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore.

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On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 153 RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) To: Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected]

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I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation.

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Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area

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Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 154 Foreshore Consultation Marine Planning and Foreshore Section Department of the Environment, Community and Local Government Newtown Road Wexford email: [email protected] Dear Sirs, I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1). I would also like to add my own observation that yet again, in light of the previous foreshore license application off the Kish Bank, yet another major application is being made that will for generations affect the extraordinary seascape of Dublin Bay and one of the most beautiful horizon vistas off any capital city in the world. In my readings of the European SEA Directives that true spirit of their concerns that would apply to any such application, I have, yet again, serious reservations in regard to the entire public consultation process that has again been applied to such a massive project of such impact.

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Have we not yet reached a place where the concerns of these projects and applications cannot be carried out with true genuine consultation communication and therefore the future of the protection of our beautiful bay and the parties, often NGO's and voluntary groups involved in highlighting the many genuine concerns, would be accorded a more respectful and open communication policy by the government. I respectfully advise that the public consultation process now put in place by the US government in these areas should be used as a benchmark. I would also like to add how lamentable the responsibilities and coverage of the Irish media are in respect to these applications. No decision should be taken on this application until all the concerns of the people in the below submission are thoroughly addressed and until the bigger question of if ever in the future any long term or permanent structures should ever be considered in this unique seascape SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage. The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th

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○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland. In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Wind farms, Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments.

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We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay, through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind

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currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same. To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects.

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The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over. Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 155 I want to register my objection to the above proposal Submission No. 156 I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1 Submission No. 157 The Minister for Environment, Community & Local Government Department of Environment, Community & Local Government, Marine Planning & Foreshore, Newtown Road, Wexford

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Co Wexford. Dear Minister, I wish to object to the granting of the above leases on the following grounds: 1. There would be significant adverse visual impact on protected and preserved views and prospects which are listed for protection in local area development plans in Dun Laoghaire Rathdown and Wicklow. The development would cover an area of 54 sq. km and would be visible from North Dublin to Wicklow. It would have the potential to impact on eighteen sites designated or candidates for designation as Special Areas of Conservation or Special Protection Areas. 2. The expected adverse impacts on the Dublin Bay Natura 2000 site are detailed in the submission on behalf of the Irish Whale and Dolphin Group. The Group is dedicated to the conservation and better understanding of whales, dolphins and porpoise in Irish waters. 3. The assertions re job creation and value for money are vague unsubstantiated and inadequate. 4. Misleading information is presented with regard to the electricity which would be generated. Dublin Array state (RDS display) that "when fully operational, the wind farm will be capable of generating at least 520MW of clean energy". On average wind turbines generate between 15% and 30% of their maximum capacity. For example, a 3MW turbine generates less than 1MW. It may be true that “the wind farm will be capable of” generating X amount of energy, but in the real world this will never happen. The wind doesn’t always blow, when it does blow it doesn’t always blow at the optimum speed. It is generally accepted that approximately one third of maximum capacity is actually generated. 5. The Irish east coast landscape would be sacrificed, in order to provide energy to the UK. 6. Ireland has no proper up to date system of planning for foreshore leases. As is stated by the Coastal Concern Group, a proper democratic planning framework must be put in place to protect our precious coasts and seas. I strongly support this. The Minister is charged with the responsibility for granting or refusing leases on behalf of the public and is required to make the decision “in the public interest”. I do not believe that it is in the public interest to grant the foreshore leases in this instance. Submission No. 158 I am a private individual writing to support the submission from Dublin Bay Concern on the proposed Dublin Array wind farm project on the Kish Bank (MS53/55/L1) SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK (MS53/55/L1) Background: Dublin Bay Concern is a group of ‘non political’ citizens with a shared interest in safeguarding Dublin’s foreshore and ensuring that any development within the bay protects and preserves our natural and cultural heritage.

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The group was formed in the wake of the application for a foreshore licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site investigation and exploratory well drilling on the Kish Bank, 6km from the shore. Mere months after the granting of the licence, Providence Resources Ltd surrendered the licence following a legal challenge concerning the application of the environmental impact assessment directives to the project. The Kish Bank licence application typified the problems inherent in the existing system for the regulation of development of the foreshore: inadequate opportunity for public consultation and engagement, insufficient regard for environmental issues and uncertainty for investors. Dublin Bay is a unique natural amenity for the people of Dublin. The Bay caters to a vast range of economic and leisure activities, including swimming, diving and fishing. Dublin Bay is home to an abundance of wildlife, from dolphins to whales and many hundreds of fish species. Dublin Bay Concern contend that the Bay is an amenity for all and that care and due process must prevail when considering development of the foreshore. Some interesting figures from Failte Ireland on Dublin: ○ Dublin attracts more tourists than any other county in Ireland. ○ According to Failte Ireland, 3.8 million overseas tourists visited Dublin in 2011 ○ In the entire country 15 out of 19 of the most popular tourist attractions visited are in Dublin. In a Failte Ireland survey on the most important reasons for visiting Ireland: ○ Beautiful scenery ranked 3rd (after friendliness and safety) ○ Natural attractions ranked 4th ○ Unspoilt environment ranked 6th. ○ The percentage of tourists whose expectations were satisfied ranked between 91 and 93%. These are compelling statistics and show how important a resource Dublin Bay is, a resource that is worthy of our protection and conservation. Special Area of Conservation: Dublin Bay Concern recently supported Minister Jimmy Deenihans’ proposal to designate 27,000 hectares of Dublin Bay as a special area of conservation. Dublin Bay Concern together with The Irish Whale and Dolphin Group and Birdwatch Ireland sent submissions to the Minister and outlined particular common concerns which also related to this submission: The Harbour porpoise, which is an Annex II species (EU Habitats Directive) is entitled to strict protection, has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service. Acoustic detection rates were the highest recorded anywhere in Ireland.

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In addition the Purple Sandpiper and Tern colonies present in the area are protected by the EU habitats directive. Dublin Array Application for Foreshore lease: We are all in favour of green energy methods but these too must follow an ethos of environmental protection which requires proper and extensive environmental impact studies to be carried out. It is our view and the view of other groups, including The European Platform against Windfarms Coastal Concern Alliance, The Irish Whale and Dolphin Group and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array proposal. An extract from the EIS provided by Saorgus as part of their application states: ‘More knowledge and experience are needed before definite conclusions on impacts can be drawn “Whilst research is on-going on certain impacts, e.g. underwater noise, electro-magnetic fields, bird displacement, public perception, there are also several aspects of offshore wind-farm developments where the effects are fully understood (e.g. suspended sediment concentrations from monopile foundations installation and cable laying; scour pit development around monopiles; seabed morphological effects within arrays of monopile foundations and species composition and rates of organisms colonising the sub-sea structures). Only a relatively small number of developments are operational so the determination of definitive trends is not possible. " An international website has been set up by OSPAR to pool information and data on environmental impacts associated with this industry (www.environmentalexchange.info) companies. This site is a voluntary site for wind energy companies who are interested in the effects of turbines on the environment. The contents of the website are not encouraging. It is not easy to find out about the effect or recent studies on effects of wind turbines on the environment. It is obvious from this that these companies need help and guidance and rules in order to care for and be interested in the effects of their developments. We would recommend that existing offshore wind farms introduce a system of data collection with regard to birds and sea life that would be helpful in building guidelines and making this type of energy safe and clean and respectful to place and living things in the future. This should be a prerequisite to licensing. There is no mention in the proposal of mitigation when pile driving. If this farm is to go ahead in some form or other surely mitigation has to be part of the licensing requirements since the area around it is a migration path for cetaceans and protected bird species, home to seals and other species that have aural sensitivities. The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed turbines has environmental consequences that are difficult to comprehend. How much concrete will be poured into this area and how much of the sand banks will be destroyed during the construction phase? Job Creation? We must look to the UK when we consider Ireland’s wind turbine future and the possibility of job creation. The UK government recently encouraged MPs to sign a letter to No.10 in February of this year saying that “In these financially straitened times, we think it unwise to make consumers pay,

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through taxpayer subsidy, for inefficient and intermittent energy production that typifies wind turbines”. There is growing consensus in the UK that onshore and offshore wind farms have been a massive waste of time and money. Despite the regressive subsidy, despite tearing rural communities apart, killing jobs, despoiling views, erecting pylons, felling forests, killing bats and eagles, causing industrial accidents, clogging motorways, polluting lakes in Inner Mongolia with the toxic and radioactive tailings from refining neodymium, a ton of which is in the average turbine — despite all this, the total energy generated each day by wind has yet to reach half a per cent worldwide Among the examples of extremely high subsidies effectively for job creation is Greater Gabbard, a scheme of 140 turbines off the Suffolk coast. It received £129million in consumer subsidy in the 12 months to the end of February, double the £65million it received for the electricity it produced. It employs 100 people at its headquarters in Lowestoft, receiving, in effect, £1.3million for every member of staff. The London Array, Britain’s biggest wind farm, with 175 turbines, employs 90 people at its base in Ramsgate, Kent. The array, which is 12 miles offshore, became fully operational in the spring. The foundation predicts its Renewables Obligation subsidy in its first year of full operation will be £160million — effectively £1.77million per job. We will leave the last word on the cost of near shore wind farms to Minister Rabbitte…. 18 JANUARY 2012 Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said. "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." http://debates.oireachtas.ie/dail/2012/01/18/00013.asp#N2) Visual Impact The visual impact of these enormous turbines cannot be understated. We are famous worldwide for the beauty of our coastlines and to blot our coastline with these huge 160 meter high turbines that deliver no economic or environmental benefit to Irish citizens is beyond comprehension. In the UK recently David Cameron responded to campaigners who have said that the planning system remains loaded in favour of developers and that too little of the countryside is protected from their spread. He signalled that local people would have more say over wind farms in their areas. Developers would have to offer much greater compensation for building them, and planners will be compelled to take into account their visual impact and the views of locals. We would call on the Irish government to do the same.

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To put the Dublin Array proposal in a visual context, one must remember that each wind turbine is 160 meters high. Liberty Hall, Ireland’s tallest building is only 59 meters high and the Stena HSS is only 24 meters wide and will be dwarfed by the 145 turbines. We currently have record numbers of tourists visiting Ireland by air and sea travel. For many the first glimpse of Ireland is Dublin Bay and all its unparalleled natural beauty. If Dublin Array goes ahead we will have destroyed the unique visual that is Dublin Bay. Conclusion: The Dublin Array proposal for this massive scale project is completely inappropriate and would gravely injure the amenity of the whole of Dublin Bay from Howth to Greystones. The entire character of the bay would be destroyed, visually as well as environmentally and at just the time when the Bay-wide cycle-path is due to begin construction. The impact of the industrialisation of Dublin Bay for the million and more people living in this area and those visiting it would be extremely negative and would cause irrevocable damage, destroying the integrity and value of this irreplaceable resource. The Dublin Array website abounds with promises of job creation, security of energy supply, meeting renewable energy targets and national economic benefits ,with no data to support these statements http://www.dublinarray.com/benefits.html. It is also clear that electricity generated from this array is primarily destined for the UK grid as Eirgrid does not (nor will between now and 2023) have the capacity to utilize the vast majority of the energy generated by this array .To our knowledge, the necessary permissions for Eirgrid connections have not yet been granted for this project, for the above reason. Dublin Array will therefore be effectively part of the UK grid but located in an environmentally sensitive area of Irish near shore. On foot of recent Foreshore licence and lease applications Dublin Bay Concern are campaigning to safeguard our bay from highly unsuitable developments and developments that provide no benefit to the Irish people in terms of energy supply, employment or profit and where public consultation is extremely poor. The Aarhus Convention, which the Irish government ratified in 2012, should go some way to improving public and community consultation in future projects. The recent granting and subsequent surrender of the foreshore license by Providence Resources, the SAC proposal designation and the Marine Area Development Bill has raised a new level of awareness amongst citizens living across Dublin Bay. There is renewed and growing commitment to conserving and protecting this beautiful, delicate and vital natural amenity for present and future generations. Coastal Concern Alliance have brought into focus and highlighted the inadequacies of foreshore legislation and the wind farm issue over 6 years ago. We support Coastal Concern in their efforts to reform this important area. The government must safeguard the maritime environment that we are privileged to have surrounding us and ensure proper planning and development is established in this area. The government has an obligation to implement and uphold the Aarhus Convention, to truly engage with communities on issues that are of vital importance to them. There is currently a case before the High Court seeking to enforce a UN decision that both the EU Strategic Environmental Assessment and the Irish Renewable Energy Plan are flawed because they did not meet the requirements of the Aarhus Convention, which requires access to information, public participation and access to justice to challenge decisions. There should be no foreshore leases or licences granted anywhere in Ireland until that case is over.

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Finally, we call on the Minister to refuse the subject application on the grounds that to make a decision on a Foreshore Lease application made in relation to The Dublin Array wind farm proposal would be premature. It is understood that the Department is undertaking a major review of licensing and leasing procedures under the Foreshore Acts. It is further understood that there is no developed policy on renewable energy, large wind farms such as the subject of this application nor oil or gas exploration and extraction such as the recent Providence application at inshore locations (i.e., locations where such activity is likely to result in more significant impacts on residential populations, on important coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such defined policy, there is no basis on which to make a decision on the subject application. Submission No. 159 TO: Dept of Environment, Saorgus Energy Ltd FROM: RE: Submission regarding the application by Kish Offshore Wind Ltd and Bray Offshore Wind Ltd for Foreshore Licenses for the Dublin Array Wind Farm. As an adjunct lecturer in environmental legislation and planning & risk management, at ____ University, I make the following comment: DEVELOPER: The Environmental Impact Statement (EIS) has been prepared by Saorgus Energy Ltd. Saorgus Energy Ltd Is a privately-owned Irish company. It specialises in the development of large wind energy sites in Ireland and has interests in several large projects. This company developed the Derrybrien Wind Farm in Galway. The Derrybrien wind farm project was the biggest ever wind farm in Ireland at the time and one of the largest in Europe. The European Court of Justice ruled against Ireland in a case involving the Derrbrien wind farm project where a landslide killed 50,000 fish in 2003. The court said that a proper environmental impact assessment should have been carried out before the project proceeded. In June 2003, the Derrybrien Project was sold to Hibernian Windpower Ltd. Saorgus Energy continues to own the site which is leased to Hibernian. NEED FOR THE ARRAY According to the EIS: "Irish and UK Governments signed a Memorandum of Understanding on Energy Trading on January 24th 2013. The revenue of the project in this case will come from sales of electricity onto the UK market together with a market-based investment support initiated by the UK Government. The exact nature of such a scheme is dependent on measures yet to be introduced by both Governments. However, it is clear as of the time of writing in February 2013 that both Governments wish to encourage Irish export projects such as Dublin Array. In this sense, it is important that projects such as Dublin Array are ready to proceed to construction once the relevant enabling framework is put in place by the authorities. Dublin Array is completing the necessary consenting programme in parallel with these government initiatives."

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There is no formal contract, between the Irish and UK governments, and such a contract may or may not be signed, depending on political decisions in the future. The application is therefore premature. Basically, this project proposal seeks to construct a project in Irish waters, for supply of energy to the UK. There is no need for such a project in Ireland. No cost benefit analysis has been published, which would support such a move. OREDP The EIA states: "In late 2010, the Department of Communications, Energy and Natural Resources published the Draft Offshore Renewable Energy Development Plan (OREDP) for public consultation. The main aim of the OREDP is to establish scenarios for the development of offshore renewables in Irish waters up to 2030 and set out a longer term vision for the growth of the offshore renewable energy sector. The publication of the Draft OREDP was accompanied by a report presenting the results of a Strategic Environmental Assessment (SEA) of the potential effects that the proposals contained in the OREDP would have on the marine and coastal environment of Ireland. It is noted that three projects, including Dublin Array, are considered as ‘existing renewable infrastructure’ for the purpose of the SEA. The reality is that the SEA was never completed, and does not exist, and neither does the Dublin Array. An incomplete SEA is no SEA at all. In addition, ______ won an EU ruling with the AARHUS Compliance Committee that states that the EU and Irish renewable energy programmes are in breach of the SEA Directive, since there has been no public consultation. 2009/28/EC is also in breach of the SEA Directive, since it requires national actions plans, but does not require SEA of those plans. Currently, ______ is before the High Court, challenging the renewable energy strategy. No Foreshore Licence for development of any renewable energy projects in Ireland should take place until that case has reached its conclusion. SITE SELECTION The site is in question is within the proposed marine Special Area of Conservation, currently proposed by the Junior Minister for the Environment, under the Habitats Directive. ALTERNATIVES There has been no effective exploration of alternatives in the EIS, as is require by EU and Irish EIA regulations. SOCIO-ECONOMIC EFFECTS The claim of economic benefit to Ireland, including hundreds of jobs, is speculative, and not based on a proper cost/benefit analysis.

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VISUAL IMPACT The EIS states: "While the wind farm would be visible from many points along the coast, it would be set in the context of a landscape that has a tolerance for man-made developments." The horizon on Dublin Bay is pristine landscape, and industrialising it with a large scale wind farm will permanently scar the landscape, and adversely affect tourism. SUSTAINABLE DEVELOPMENT Overall, the project does not meet the UN, EU and Irish legal requirements of sustainable development, as it unduly places economic concerns over social and environmental ones. CALL FOR ORAL HEARING I call on the Department of the Environment to conduct an oral hearing, in accordance with the AARHUS convention, the EIA Directive, and the EU Public Participation Directive, before granting any license. There is an absolute need for cross-examination of the expert opinion proffered by the developer in this case, since on its face, it does not meet the minimum legal or policy standards. Submission No. 169 SUBMISSION TO THE MINISTER FOR THE ENVIRONMENT, COMMUNITY AND LOCAL

GOVERNMENT RE: PROPOSED DUBLIN ARRAY WIND FARM PROJECT ON KISH BANK

(MS53/55/L1)

Background:

The Dun Laoghaire Fisherman’s Group was proactive in objecting to the application for a foreshore

licence made in January 2012 by Providence Resources Ltd under the Foreshore Act 1933 for site

investigation and exploratory well drilling on the Kish Bank, 6km from the shore.

Throughout the application process Providence failed to consult with the Dun Laoghaire Fishermen’s

Group to take into account the impact their proposed operations would affect the local fishing

grounds and the members’ livelihoods. As a result of rigorous campaigning by several concerned

citizens groups and the Dun Laoghaire Fishermen’s Group, Providence Resources Ltd surrendered

the licence following a legal challenge concerning the application of the environmental impact

assessment directives to the project.

The Kish Bank licence application typified the problems inherent in the existing system for the

regulation of development of the foreshore: inadequate opportunity for public consultation and

engagement, lack of consultation with the Fishing Industry and those fishing along the East Coast

Area as well as insufficient regard for environmental and sustainability issues.

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Dublin Bay is both an economic and natural resource that is worthy of our protection and

conservation, and the Dun Laoghaire Fishermen’s Group object to any activity being undertaken in

the foreshore without proper consideration being given to the full impact on all invested parties, and

adherence to the correct and proper procedures as laid down in the Arhaus Convention.




It is our view and the view of other groups, including Dublin Bay Concern,

The European Platform against Wind Coastal Concern Alliance, The Irish Whale and Dolphin Group

and Save Our Seafront, that this has not been done adequately in the case of the Dublin Array

proposal.






















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The sheer scale of this project, involving 54 km2 of the near shore, and the size of the proposed

turbines has environmental consequences that are difficult to comprehend. There is extensive

fishing going on in this area and this will cause total disruption and complete loss of area for:

Commercial and sport fishing, sailing and all other recreational water activities in the area. The

licence application has not outlined what the proposed exclusion zone would be and has not

conducted any impact assessment to the affected activities and parties. For example, How much

concrete will be poured into this area and how much of the sand banks will be destroyed during the

construction phase? The proposed site will be subject to constant erosion which will require on-

going maintenance. How will this affect the surrounding water activities, both commercial and

recreational?

Job Creation?





turbines”.











member of staff.






18 JANUARY 2012





286








Visual Impact
















Conclusion:

















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On foot of recent Foreshore licence and lease applications The Dun Laoghaire Fisherman’s Group

alongside other concerned groups such as Dublin Bay Concern are campaigning to safeguard our bay

from highly unsuitable developments and developments that provide no benefit to the Irish people

in terms of energy supply, employment or profit and where public consultation is extremely poor.

The Aarhus Convention, which the Irish government ratified in 2012, should go some way to

improving public and community consultation in future projects. The government has an obligation

to implement and uphold the Aarhus Convention, to truly engage with communities on issues that

are of vital importance to them. There is currently a case before the High Court seeking to enforce a

UN decision that the Daft Irish Renewable Energy Plan is flawed because it does not meet the

requirements of the Aarhus Convention, which requires access to information, public participation

and access to justice to challenge decisions. There should be no foreshore leases or licences granted

anywhere in Ireland until that case is over.









surrounding us and ensure proper planning and development is established in this area. It is

understood that the Department is undertaking a major review of licensing and leasing procedures

under the Foreshore Acts. It is further understood that there is no developed policy on renewable

energy, large wind farms such as the subject of this application nor oil or gas exploration and

extraction such as the recent Providence application at inshore locations (i.e., locations where such

activity is likely to result in more significant impacts on residential populations, on important

coastline habitats and on coastal leisure, fishing and tourism activities). In the absence of such

defined policy, there is no basis on which to make a decision on the subject application, and as such

the Dun Laoghaire Fisherman’s Group would like to have their strong opposition to this proposal as

it now stands, noted and taken into account when consideration is being afforded to the application.

Signed

The Dun Laoghaire Fisherman’s Group

submission no. 4 to whom it may concern...1 submission no. 4 to whom it may concern: i would like to...

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