Wind Submission,
Planning Section,
Department of the Environment, Community and Local Government,
Custom House,
Dublin 1.
To whom it concerns,
I believe that is imperative that any review of the Guidelines must also examine all economic, social and
environmental issues of wind and grid planning and development. An examination and resolution of these
issues is a prerequisite to any location, setback, noise, flicker discussion. In my opinion the government
has failed in its reassessment of the guidelines based on the narrow focus of the review. It is imperative
that any review of the Guidelines also examines all economic, social and environmental issues of wind
and grid planning and development. An examination and resolution of these issues is a prerequisite to any
location, setback, noise, flicker discussion. This review is not in keeping with the Aarhus Convention.
Setback Distances
The Wind Atlas for Ireland has a regard only for wind harnessing up to 100m and setback distances reflect
the consequent expected turbine height. The new draft guidelines do not make note of new heights in the
establishment of the setback distances. A default set back of 10 x base to tip height is required.
This recommendation is based on conclusions by many experts, such as Dr Chris Hanning, Consultant in
Sleep Disorders, UK who discusses adverse impacts on sleep at distances of up to 2km and greater,
based on a turbine height of 125m. Also the Deputy Chief Medical Officer, Dr. Collette Bonner, advised
Minister Jan O’Sullivan’s department (Nov 2013), in response to a request for input to the WEDG revision
process, that "there is a consistent cluster of symptoms related to wind turbine syndrome which occurs in
a number of people in the vicinity of industrial wind turbines. There are specific risk factors for this
syndrome and people with these risk factors experience symptoms."
This setback is needed to reflect the new developments in wind turbine technology where the height and
the size of the turbines is increasing all the time. New heights currently being proposed range between
150m -190m. This may well increase as wind continues to be harnessed more competitively into the
future.
Setback and Tourism
Insensitively sited wind energy developments and the impact on tourism and tourism potential have to be
noted in setback distances. Tourism is a very important and very often the only source of economic
stimulation in many rural parts of Ireland. Setback distances have to make note of the sensitivity of
landscapes dependent on tourism and with burgeoning or potential tourism developments.
Ability to check for correct setback, visual impact and flicker impact.
In setting out the zones of visual influence / zones of theoretical visibility, it should be possible for
communities and individuals to check the consistency of the software calculations used by wind
developers against an independent system at planning offices/ libraries for their area of concern. It is very
difficult for communities and individuals particularly in rural areas with small populations to raise the funds
necessary to go through the planning submissions for these developments and generate independent
photomontages and wireframes etc. to verify the proposals. This is the case in particular for the tall
turbines where the scale is completely alien and hitherto unseen in the Irish rural landscape. People will
require assistance with this in the years ahead. In regions where development of the scale and level of
industrialisation over such a wide area of landscape, has not been experienced previously, it is essential
that the development is understood. It may be difficult for people unfamiliar with the scale of some
turbines (their height and extent) to visualise the impact it will have on the landscape they inhabit.
Minimum Setback
Provision of derogation from the minimum set back distance by written agreement with the landowner will
allow for abuses of the system especially in cases where home/landowners may not be able to visualise
the extent or scale of the proposed development. Legal advice alone cannot counter this. This process
must not be allowed.
Setback in the Context of Landscape and Visual Impact.
Landscape Character and Landscape Capacity have to be regarded as extremely important in the
determination of setback distances. Visual Impact and Landscape Character Assessment are more
integrated when one regards the totality of landscape as a visual experience. I note they are separately
categorised in the guidelines. To that end, I have set out here below some instances in landscape
planning and visual impact assessment which relate to setback distances.
Setback Distances and the Cultural Landscape
The landscape character in the republic although sharing many similarities differs from that of Northern
Ireland and Scotland. It is different from England and Wales and contrasts completely with the cultural
landscape of continental Europe. This is because of the fine relationship between the cultural landscape,
walls, hedgerows, farmsteads, out houses and building with the wider farmed or anthropological
landscape. The overlay of the matrix of the anthropological landscape on the underlying landform
influences the landscape character. The visual relationship is very fine in nature where not disturbed or
hitherto industrialised. I note the guidelines categorise just six landscape typologies. There are an
extraordinary number of landscape character types in Ireland due to the relationship of the cultural
landscape. This does not take note of the anthropogenic landscape and the change to the landscape
character where setback distances make no account of the relationship of buildings and structures with
the landscape. It is not enough to establish a setback distance from a house and have no regard for its
visual relationship to e.g. the fine matrix of walls, outbuildings, hedgerows, orchards and field systems etc.
of which it is a part. Setback distances will have to take these aspects of landscape character into
consideration also in individual cases.
Setback Distances and Archaeological Landscapes
Similarly setback distances from archaeological monuments must also take their position in the wider
archaeological landscape into consideration and must note the landscape type in the first instance as the
receiving environment. Thus the setback in certain cases will be from a particular landscape.
Setback Distances and the Designed Landscape
There are many examples of landscape design both historical and contemporary all over Ireland. Again
the setback distance has to have regard for the designed landscape in the context of its landscape setting.
The guidelines don’t allow for setback distances from a landscape type in this respect.
Setback Distances and the Historical Landscape
There are many examples of historical landscapes throughout Ireland. The guidelines don’t make
reference to the historical landscapes and aspects of historical landscapes – railway lines, old bridges, mill
races etc. and the setback distances required.
Setback Distances and the Cumulative Impact of Multiple Wind Developments
In the establishment of setback distances the cumulative visual impact of a wind development in the
context of an existing or proposed development must also be considered. A minimum setback distance
will not in itself suffice to satisfy the cumulative impact of two or more developments.
Setback Distances and Health
Health Impact Assessment do not currently influence the setback distances. This should be included in
accordance with WHO best practice guidelines with respect to the implementation monitoring and the
evaluation of the S28 Guidelines.
We believe that a key objective should be the protection of sleep. Sleep is a human right, not an amenity
as stated and cannot be protected by a 40dB absolute limit.
Noise
The experience of the Irish rural landscape as for all landscapes is not simply visual. The sense of an
ability to escape from noise and to have nature nearby is an important facet in modern life as indicated by
many volumes of research. To this end, there is no mention of a baseline noise monitoring requirement in
the guidelines. In the case of very quiet rural areas e.g. 5dB, a minimum value needs to be set separate
from other acceptable levels. 40Db is too loud in such a situation. This is important in areas where people
are living, frequently visiting or where outdoor activities are important to and in the area. The EPA
Environmental RTDI Programme defines the Environmental Quality Objectives for how ‘Quiet Areas’ are
to be protected in Ireland to comply with the EU Noise Directive. Furthermore submissions made by world
leading Acoustician Dick Bowdler must also be considered.
The Marshall Day Report highlighted the need to deal with special audible characteristics of wind turbine
noise. It is of significant concern that although the Minister purports to take an evidence approach to the
WEDG Review, they have ignored an evidenced approach where their experts have suggested same.
Therefore it is imperative that the WEDG Review includes an evidenced based approach to dealing with
Amplitude modulation, Impulsiveness, Infrasound, Low frequency noise and Tonality as recommended by
Marchall Day.
Shadow Flicker
The strategy points out that shadow flicker “occurs inside buildings” it make no provision for the
occurrence of flicker on the open country side. Surely consideration should be given to the potential
distracting and dazzling effect that this will have on drivers and other road users, amenity users and
wildlife as well as livestock and domestic animals.
Impacts on Autistic Children living in the vicinity of the site. A survey by Davis and Steigler (2010) of over
17,000 children who have Autistic Spectrum Disorders (ASD) shows that over 40% were “hypersensitive
to sounds” and that “noise sensitivity is a particular problem” for children with ASD. I would consider it
mandatory that the Government make it a requirement in the issuance of guidelines to planning authorities
that a thorough impact on autistic children be assessed.
Property Values
There is increasing recognition of the negative impacts of wind farms on nearby houses. In particular,
Linconlshire Valuation Tribunal (2525475645/032C and 2525475651/032C) upheld an appeal to
downgrade a dwelling to a lower council tax band due to the proximity of a wind farm which was 930m
from the house in question. The findings of the appeal explicitly states “Case law and experience
elsewhere had shown that dwellings which were located in close proximity to wind farms had seen their
property prices drop by around 20%.” The devaluation of property must be given serious consideration in
any Cost benefit analysis conducted.
I hope that the government will take cognisance of our observations and in particular our opinion
regarding the limited scope of this revision.
Pat Guinan.