XXXXXXX,
Co Clare.
Telephone (XXXXXXXX
Mobile
(XXXXXXXX
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Wind Submissions,
Planning Section,
Department of the Environment, Community and Local Government,
Custom House,
Dublin 1.
21st February 2014
By email to: windsubmissions@environ.ie
Re: Response to Wind Energy Guidelines Focused Review: Draft statutory guidelines.
Dear Planning Section,
I have had involvement in the wind industry in Ireland for ten years, from the position of a land owner
where developers wish to build a wind farm on my family land and I hope that this will happen soon, to a
project manager who has worked over the last five years using the existing guidelines and best practise
to get planning permission for wind farms as well as overseeing the construction stage, development and
running of wind farms in rural Ireland. I am now looking at the options of a single turbine on my own
farm and by using best practice and the current guide lines I know that I will have no issue with the local
community in relation to noise, flicker or set back distances.
We welcome the opportunity to respond to the DoECLG public consultation on the Wind Energy
Guidelines Focused Review: Draft statutory guidelines. We support the IWEA response to this
consultation, and would like to reiterate that clear planning guidance is crucial to ensure community
confidence in the consistent standards being applied, and provide a stable policy framework to allow the
industry, which now employs over 3400 people to make the clear and necessary progress towards our
2020 targets.
We support the positions taken by IWEA and would like to reiterate the following points:

We believe that the scale of the response proposed by the Department stands
disproportionately with the lack of evidence of issues actually being encountered under
the current guidelines, despite there being over 2GW of wind energy now operating in
Ireland

The proposed use of an absolute 40dBA day and night noise limit is unnecessary,
unsubstantiated and wholly conservative. It is not clear how this figure has been arrived at, as
the setting of such a limit is out of line with the findings of the Marshall Day study. We also
believe the Irish approach as proposed in the Proposed Revisions is grossly out of step with
International and particularly European approaches, and will if implemented be severely
detrimental to continuing viable wind development in Ireland.
While strongly suggesting that the existing noise framework be retained, we propose that if the
Department is minded to change to a 40dB limit that it should be 40dB LA90 10min, or a maximum
increase of 5dB(A) above background noise (whichever is greater). The criterion should be
Mr George Tottenham
XXXXXXX,
Co Clare.
Telephone (XXXXXXXX
Mobile
(XXXXXXXX
Email Address XXXXXXXX@XXXXX.net

assessed for both day (07:00 to 23:00hrs) and night time (23:00 to 07:00hrs) periods. This
approach would be in line with the UK best practice under ETSU-R-97.
There is a concern that a setback distance if it is to be established must include a clear limitation
from the turbine to the receptor as per Irish industrial norms. As currently proposed the
Guidelines would include an ill-defined “curtilage” and “special amenity” area which could cause
confusion for planners and developers, and possibly lead to increased setback distances. We
propose that if it is to be maintained, the concept of “curtilage” be more strictly defined to a
radius of 20m for planners in line with international best practice under the UK best practice
standard ETSU-R-97 Assessment and Rating of Noise from Wind Farms1 and the IOA Good
Practice Guide on Wind Turbine Noise2.

An absolute exclusion on shadow flicker as proposed would be un-implementable for wind farm
developers as the prospect of shadow flicker for even a short period of time in a year would
provide cause for issue which is wholly unreasonable. We ask that the International
recommended limits for shadow flicker of 30 hours per year or 30 minutes per day for receptors
within 500 metres which have proven effective in Ireland and internationally are maintained. We
suggest a strict planning condition provision ensuring wind farm developers bring forward rapid
remedy in the extremely rare situations where an issue should arise.

While welcoming the proposed flexibility, greater certainty and clarity on exceptions there are
three points we would like to raise:
1. Firstly exceptions to the noise limits should be clarified in line with the UK best practice
ETSU–R-97 Guidelines on noise limits for persons with a financial involvement.
2. Secondly exceptions to the setback limit should be explicitly mandated under the Guidelines
replacing “may” to “will” in the first line of the text on page 8.
3. Thirdly in line with the approaches taken under noise and setback for there to be the
possibility of a similar exception to be provided for in the rare situation of shadow flicker
arising.
Finally, we have large practical questions of how compliance will be assessed at pre-application (rather
than pre-construction) and call for this detail to be fully consulted on along with the necessary
appendices vital to allow for clear and factual scrutiny of the evidential and factual detail on which the
Proposed Revisions rest.
1
http://www.hayesmckenzie.co.uk/downloads/ETSU%20Full%20copy%20(Searchable).pdf
http://www.ioa.org.uk/sites/default/files/IOA%20Good%20Practice%20Guide%20on%20Wind%20Turbine%20Noi
se%20-%20May%202013.pdf
2
Mr George Tottenham
XXXXXXX,
Co Clare.
Telephone (XXXXXXXX
Mobile
(XXXXXXXX
Email Address XXXXXXXX@XXXXX.net
In conclusion we would like to thank Department for the opportunity to engage on this issue and to
highlight the particular importance of this consultation given the significant implications it has for the
continued viability of the wind sector.
Yours sincerely
*sent by email, requires no signature
_______________
George Tottenham
Mr George Tottenham