As a community group living in a recognized and recorded area of flood risk, JMAG is acutely aware of the urgency of climate change. We therefore are fully supportive of the Paris Agreement and the achievement of the Government’s subsequent 2020 renewable energy targets. Cognisant of these targets it is clear to us that solar energy will be an important component of the country’s future energy mix. We feel that it is therefore not only logical, but responsible that the government ensures that solar-specific policy, legislation and planning guidelines be enacted to ensure best practice and a strategic, plan-led approach to this new industry in Ireland.
Due to the grant of planning to solar farms on ad hoc sites around the country, despite the absence of solar-specific planning guidelines within the planning legislation, we are concerned at the complete lack of government policy in relation to solar. In the past 18 months Ireland has witnessed a ‘gold rush’ effect with respect to the emerging solar sector, with hundreds of speculative applications being submitted to local authorities prior to the consultation and decision on a new government Renewable Energy Support Scheme (RESS).
As a result of the current legislative vacuum for solar energy:
• planning permission is being granted to sites on an ad-hoc basis which is essentially being driven by opportunistic developers who are flooding the planning system with applications, rather than a governmental-led strategic vision.
• there is failure to learn from the experience and best practice of other countries in identifying alternative solutions to siting these developments, such as brownfield sites including previously developed land, covered landfill that cannot be farmed or developed for housing, commercial and industrial roofs and homes.
• planning is being awarded to sites without taking into consideration the capacity of the grid to accept the energy. We refer specifically to the decision paper by the Commission for Energy Regulation “Connection Policy: Transitional Arrangements”, dated 12/10/2016 which notes that “the system operators have indicated that the volume of wind and solar applications is not manageable” and that “the scale of applications received to date from wind and solar projects far exceeds what can be practically and effectively delivered.”
• there are no solar-specific guidelines by which council planners can make strategic and informed decisions regarding the complexities of awarding planning to such developments or by which communities can make valid objections or by which An Bord Pleanála can fairly adjudicate solar planning decisions.
• solar developers are attempting to use the fast-approaching 2020 targets and potential fines as leverage to lobby for a favorable solar tariffs which will significantly increase the PSO levy and will likely impact negatively on the public’s support for renewables.
We feel there has been no government foresight in relation to this issue, given the pace at which solar developers are submitting applications to planning offices around the country. According to the IFA, 6,000 acres of agricultural land was committed to solar developers in July 2016. This had risen dramatically in a few months to 20,000 acres by October 2016, and no doubt has continued to rise.
Again, we understand and support Ireland’s commitment to increasing its renewable energy capacity and usage; however, we fear that the absence of solar-specific policy and legislation, and the aggressive pace of applications from solar developers is and will continue to result in incoherent and uncontrolled development of the solar energy sector in Ireland.
White Paper Ireland’s Transition to a Low Carbon Energy Future 2015 – 2030
Commission for Energy Regulation “Connection Policy: Transitional Arrangements” 12/10/2016 http://www.cer.ie/docs/001060/CER16284%20Transitional%20Arrangements%20-Decision.pdf
1996 Wind Energy Guidelines for Ireland http://www.housing.gov.ie/sites/default/files/migrated-files/en/Publications/DevelopmentandHousing/Planning/FileDownLoad%2C1633%2Cen.pdf
Draft Revisions to Wind Energy Guidelines for Ireland (http://www.seai.ie/Renewables/Wind_Energy/Wind_Farms/Wind_Farm_Development/Guidelines_for_wind_farm_development/
Ireland’s Draft National Mitigation Plan – consultation closed on 26 April, 2016 http://www.dccae.gov.ie/documents/National%20Mitigation%20Plan%20April%202017.pdf
PSO Levy 2017/2018 – Proposed Decision Paper – deadline for responses 30 June, 2017 https://www.cer.ie/docs/001138/CER17115%202017-18%20Public%20Service%20Obligation%20Levy%20Information%20Note.pdf
REFIT Schemes and Supports http://www.dccae.gov.ie/en-ie/energy/topics/Renewable-Energy/electricity/renewable-electricity-supports/Pages/REFIT-Schemes-and-Supports.aspx
• “Planning guidance for the development of large scale ground mounted solar PV systems”
BRE National Solar Centre, Cornwall with contribution from Cornwall Council, October 2013
• “Planning practice guidance for renewable and low carbon energy” Department for Communities and Local Government, July 2013 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/225689/Planning_Practice_Guidance_for_Renewable_and_Low_Carbon_Energy.pdf