Wind Submissions
Planning Section
Department of the Environment, Community and Local Government
Custom House
Dublin 1
By email to: windsubmissions@environ.ie
19 February 2014
Re:
Proposed Revisions to Wind Energy Development Guidelines 2006
- Targeted Review in relation to Noise, Proximity and Shadow Flicker
Dear Sir/Madam,
This submission is made by Robert J Goff & Co plc. (“Goffs”), Kildare Paddocks, Kill, Co Kildare. Goffs
are Bloodstock Auctioneers and have been selling horses in Ireland since 1866. In 2013 Goffs sold
3,459 horses for €99,336,600 headed by a top price of €6,000,000 which was a European record for
the category. We welcome buyers from 30 different countries each year and are Ireland’s Premier
Thoroughbred Auction House.
We are 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 17 February 2014.
The Irish thoroughbred industry is under threat by a new generation of large scale industrial wind
turbines which are an 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.
(a)
Targeted revisions to Wind Energy Guidelines should prevent the potential negative impact
of wind farm proposals 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), and
(b)
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 will result in a flight of capital from Irish studs and stables. It may also be a
significant deterrent to future funding and support by overseas investors, who are integral
to the industry.
Therefore,
 thoroughbred breeding facilities, such as stud farms, stables, 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 land uses 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 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 and training facilities’.
Yours sincerely,
HENRY G BEEBY
Group Chief Executive
Robert J Goff & Co plc.