Wind Submissions,
Planning Section,
Department of the Environment, Community and Local Government,
Custom House,
Dublin 1.
By email to:
windsubmissions@environ.ie
February 19th, 2014.
Re:
Proposed revisions to Wind Energy Development Guidelines 2006
Targeted review in relation to Noise, Proximity and Shadow Flicker
Dear Sir/Madam,
The Association of Irish Racecourses Limited is the representative body of all 26 horse
racecourses on the island of Ireland. The thoroughbred horse racing and breeding industries in
Ireland are inextricably linked and interdependent with racecourses being the shop window of
the breeding industry. Irish racecourses run 350 race meetings per annum that accommodate over
29,000 equine participants the vast bulk of which are Irish bred.
I am writing in support of the joint submission made by Irish Thoroughbred Breeders’
Association, Association of Irish Racehorse Owners, Irish Jockeys Association and Irish
Racehorse Trainers Association dated February 17th, 2014 and from which you will already be
aware of the importance of the thoroughbred racing and breeding industry to this country in
terms of rural employment, economic contribution, international reputation and foreign
investment.
The Irish thoroughbred industry considers itself under threat by a new generation of large scale
industrial wind turbines which are incompatible land use with the established thoroughbred
industry in this country. Revisions to the 2006 Wind Energy Development Guidelines should not
facilitate clear threats to the viability of the Irish thoroughbred industry.
Targeted revisions to the Wind Energy Guidelines should prevent the potential negative impact
of wind farm proposal on the safety of thoroughbred horses and personnel, in particular, ridden
horses, because of the very real risk of thoroughbreds being adversely affected by turbines being
located directly within their range of vision or hearing (noting thoroughbred horses’ highly
evolved flight response and their particular sensitivity to perceived visual or auditory threats).
Targeted revisions to Wind Energy Guidelines should prevent the visible encroachment of wind
turbine developments on the undisturbed rural landscape of stud farms and training yards which
could result in a flight of capital from Irish studs and stables. It may also be a significant
deterrent to future funding and support from overseas investors who are integral to the industry.
As a consequence of the above I would specifically request that:

Thoroughbred breeding and racing facilities such as stud farms, stables, racecourses,
training yards and gallops should be added to the Wind Energy Development
Guidelines’ definition of ‘Noise Sensitive Property’ at Section 5.6.6 of the amended
text to acknowledge the specific vulnerability of the industry to incompatible use such
as wind farms;

Additionally, noise limits referenced in Section 5.6.8 should be amended to apply at
the boundaries of these thoroughbred breeding and racing facilities;

Separately, the definition of ‘other affected property (e.g. existing work places or
schools)’ in section 5.12.1, relating to Shadow Flicker, should be amended to include
‘thoroughbred breeding, racing and training facilities’.
Yours sincerely,
______________________
Paddy Walsh
Chief Executive