Dear all, 

Tomorrow the 7th August at 5.30pm is the closing date and time to submit an observation to Bord Pleanála Case reference: OA27.319864 regarding the proposed offshore wind energy development - Arklow Bank Wind Park 2.

Find below a prepared observation document for you to submit. 

Should you feel compelled to do this, copy and paste the comprehensive observation below into a Word Document in Letter Format and follow the simple instructions at An Bord Pleanála at this link to upload it. | Observation on a Marine Application (pleanala.ie). Please also include your own personal observations and concerns about this project.

Put your hand up and say how you feel and why you care. 

It is important for An Bord Pleanála to understand the demographic reach that this project may affect, including families, business owners, retired citizens, local and foreign tourists. 

We will continue to advocate for sustainable macro-siting of offshore windfarms in Irish waters until the deciding date for this case on 10th December 2024.

Thank you for your support, 

 

The members of South East Coastal Protection Alliance

 

Prepared Observation to be submitted as a Word Document in Letter Format

 

Offices of An Bord Pleanála, 64 Marlborough Street, Dublin 1

Re: Case Reference OA27-319864 Proposed Offshore Wind Energy Development Sure Partners Limited - Arklow Bank Wind Park Phase 2 

Submission By:  

Name: 

Address: 

Email: 

Dated:

Observations:

To whom it may all concern,

I wish to make an observation opposing the Planning Application submitted by Sure Partners Ltd (SSE Renewables) for permission to develop an offshore wind energy development - Arklow Bank Wind Park 2 - on the Arklow sandbank in Co. Wicklow.

This project has the capability to cause significant damage to the important and sensitive Arklow sandbank ecology and its associated coastline both during the construction, operational and maintenance phases. The Aarhus Convention protects: “The right of every person of present and future generations to live in an environment adequate to his or her health and wellbeing.”  All evidence suggests that this project needs to be located on a more environmentally sustainable site.

I and many others, believe it is neither unreasonable or too late to ask the Irish government and An Bord Pleanála, to deliver safe, secure renewable energy and to protect our beaches and biodiversity. 

This proposal is not compliant with the EU guidelines and directives and the transposition of such in Irish Law; 

The proposed Arklow Bank Wind Park 2 site itself and in-combination with other nearshore wind projects intersects with or is in close proximity to registered Natura 2000 sites. The Arklow Bank is defined as "a sandbank slightly covered by seawater at all times" and is recognised as an Annex 1 conservation site under the EU Habitats Directive. The Nature Restoration Law states that EU countries should, prioritise restoring habitats that are located in Natura 2000 sites. These areas are “essential” for nature conservation, the law says, and there is an existing EU obligation to ensure that Natura 2000 areas are covered by long-term restoration measures.  The protection of biodiversity must be at the core of offshore renewable energy and an ecosystem-based approach to Marine Spatial Planning must be undertaken for all Irish waters, as is required under the Directive 2014/89/EU (‘Marine Spatial Planning Directive’).
Therefore, this site is not an appropriate location for an offshore windfarm of this scale. 

The Arklow Bank is a 'headland associated' sandbank, one of only two in Ireland, the other being the Burford Bank just out from Dublin Bay. There are studies that show if the elevation of such sandbanks is highered or lowered, it can cause serious sediment/sand shift on the parallel coastline. When they are highered it causes sand to be shifted off the beach, while lowering will deposit more sand onto the beach. Since 2004, following the installation of 7 turbines on the Arklow Bank, sand has gradually disappeared off the little beach down from Ardinary and there has been a significant loss of sand on the south beach of Brittas Bay, evident from the exposed rocks near the water's edge which are not in older photos. 

In 2016, a Dumping at Sea licence was granted to remove 100,000 tonnes of sand which had built up on the eastern side of the turbines. This infers that the sandbank level has been raised, and being a 'headland associated sandbank' is causing sediment (sand) shift off the parallel beaches.

This issue is not adequately addressed in the EIAR submitted by SSE Renewables Sure Partners Ltd.  Therefore, we suggest it is both reasonable and prudent for An Bord Pleanala and the relevant state bodies to commission an independent EIAR with third-party oversight to thoroughly understand the baseline condition and demonstrative changes to the Arklow Bank and parallel coastline since 2004 prior to making a decision for further development on this European site.

In addition, there are specific concerns relating to project; 

• Construction of the project will destroy the Arklow sandbank as we know i
• Natura 2000 sites/SACs are at risk of permanent damage
• Unacceptable visual and noise impacts, both day and night may affect mental health
• Biodiversity of key species at risk of injury - Birds, Fisheries, Mammals etc
• Alternative sites have not been considered by SSE Renewables Sure Partners

Construction of the project will destroy the  Arklow sandbank as we know it

> Sandbanks are listed under Annex 1 of the EU Habitats Directive and the Arklow Sandbank is already designated as a protected habitat.   The Arklow Sandbank is 27 km long (see reference 2) and, like all sandbanks, it acts as a protective barrier to the parallel coastline. It is a natural resource and is intrinsically linked to the wellbeing and survival of hundreds of species of wildlife. 
> The developers EIAR statement shows that 190km of cables are to be installed. Along with up to 56 turbines. The SSE proposals would see 2.6 million tonnes of imported material and 96,000m3 of concrete being poured onto the Sandbank, and effectively levelling an area of 986 acres and irreparably damaging the Sandbank forever. There are no plans to decommission any of the foundations and scouring protection material installed.
> The construction of the existing 7 turbines in 2004 confirmed that development of this nature impacts the sandbank. Scouring at the base was rectified in 2005 and a dumping at sea licence was granted in 2017 to move 100,000 tonnes of material.
EIA submission quotes subdued /tepid tidal currents on the Arklow Bank.   This is incorrect as a Dumping at Sea Licence, information 2016 Section 8.5.3- provided by the existing wind farm operator, quotes Arklow bank being subject to strong tidal currents, wave heights recorded at 8/9 metres when breaking on the bank, currents of 4.5 miles per hour across the bank with tidal currents of 7 miles per hour on the eastern side  The latter assessment is in line with the experiences of fishing and sailing people in the area. 

2. Natura 2000 sites/SACs are at risk of permanent damage

> At most risk sites are 5 designated Special Areas of Conservation including the Wicklow Reef, Magherabeg Dunes, Kilmichael Sandhills, Buckroney/Brittas Dunes & Fen and the Murrough Wetlands. The obstructions built on the sandbank will alter the tidal flow and cause changes to the profile of the sandbank.  This in turn will cause a substantially increased risk of coastal erosion.
> The damaged to the sandbank will be irreparable and will not recover by the time construction is completed after 5/6 years. The Wicklow Reef (SAC) Ref 002274 in particular will be put in peril if this project is allowed to proceed. Construction disturbance and dredging will lead to sediment suspension and increased turbidity which will adversely affect marine organisms. This is the only known habitat in Ireland and the UK for the Honeycomb Worm. The effects of such large sediment movement driven by the tidal currents quoted above on the Wicklow reef and other dune / beach systems have not been adequately investigated within the EIAR. 
> The sand dune system is already being eroded on Buckroney/Brittas Dunes & Fen SAC and will continue to erode at a faster rate if this project is permitted to proceed. All the other beaches along the coastline are at significant increased risk of future erosion if this project goes ahead. 
> Independent scientific research needs to be carried out in order to establish that there will be no impact on the coast and no adverse effect on the local SAC/SPAs. An Bord Pleanála should make their own complete, precise and definitive findings and conclusions and upon which they can best determine the impact of this industrial project on these important Natura 2000 sites.

3 Unacceptable visual and noise impacts, both day and night may affect mental health to residents and tourists.

> At 287 metres tall, the proposed turbines will be the biggest that the world has ever seen, each comparable to the Eiffel Tower - and sited as close as 6 km to shore. For perspective, the turbines will be higher than these well-known landmarks - The Castletimon Hill (the Old Man) is 236m, Tara hill is 252m. Bray Head is 241m & The Dublin Spire is 121m.
> A primary concern is the considerable visual and potential noise intrusion that the turbines will impose on our scenic coastal views. The proposed steel structures will dominate the horizon creating an industrial landscape that is starkly out of place in a natural coastal environment. The new project will dominate the unspoilt seascape seen from the coast and bear no comparison to the turbines already there. These turbines will be larger, closer and in such a quantity that they will be visible from many locations along the coast both day and night as they will have red night lights installed. 
> The sea is known for its therapeutic, psychologically restorative properties. People gravitate to the sea to look at it, walk by it, swim and boat in it and to live by it. It will be impossible to escape the negative visual imposition that the turbines will have on what is an otherwise structureless landscape. Quality of sea bathing water will be severely compromised. Blue flag status is unsustainable in such an environment. What is unspoiled will become spoiled and the negative consequences on mental health need to be addressed as the EIAR states the visual impact will range from moderate to major. 

4. Biodiversity of key species at risk of injury - Birds, Fisheries and Mammals 

> Wicklow Head (SPA) is a nesting site for endangered species of birds. The Arklow sandbank is a foraging area for Kittiwakes (Red Listed) and other endangered birds (Red Throated Diver). This foraging area must be protected. 63% of Ireland's bird species are Red- or Amber-listed,  The sandbank is a foraging area for red listed seabirds nesting on Wicklow Head. This project location poses a threat to birds by blade strikes and negatively impacting their feeding grounds and foraging areas within the fertile foreshore. 
> Wicklow Reef SAC located just 3.6km away from the proposed Arklow Bank Wind Farm. There is a good diversity of species associated with the reef, including hydroids (e.g. Hydrallmania falcata), a variety of polychaete worms, the snail Calliostoma zizyphinum, the bivalves Musculus discorand Mytilus edulis, other molluscs, bryzoans, barnacles, amphipods, crabs, starfish, brittlestars and sea squirts. Three of the species associated with this biogenic reef are rare in Irish waters. Grave pollution risk from accidental oil spills /drilling lubricants and general construction activities.  There is no way for this project to mitigate against the huge amounts of sediment being released through drilling and sandwave levelling associated with the development of this area.
> Sea beds on the East Coast are an important habitat for Phytoplankton and consequently are a significant carbon sink that would be seriously disturbed and release huge amounts of carbon dioxide. Phytoplankton comprise two main groups: photosynthetic cyanobacteria and the single-celled algae that drift in the sunlit top layers of the shallow foreshore waters. They provide food, directly or indirectly, for virtually every other marine creature. They emit much of the oxygen that permeates our atmosphere. They play a huge role in the cycling of carbon dioxide from the atmosphere to the biosphere and back, and this cycling helps to control Earth's climate. The construction matter proposed for this project would critically damage this vital natural resource. 
> Sonar mapping and pile driving cause sea mammals such as harbour porpoises and seals to become disorientated and separated from each other and push them into areas where there is a lot of boat traffic (up to 66 vessels on site at any one-time during construction). The Agreement on the Conservation of Small Cetaceans of the Baltic, North East Atlantic, Irish and North Seas (ASCOBANS), for example, is significant here. This project would likely have a significant effect on the marine environment of such sea mammals and therefore must undergo a stringent and independant EIA. 

5. Alternative sites have not been considered by SSE Renewables Sure Partners

> The developers declare that this is a favourable site, but their hands are tied because it is the only site that they can look at as they are working to the MAC that has already been granted to them.  The Gov who determined the location of a Marine Area Consent (MACs) have not considered alternative sites. They rely on the existing site that were already earmarked for a Wind Farm by way of a foreshore Lease issued in 2002. This site was granted without any proper EIAR and AA and SEA being carried out. There has been no site selection oversight, instead, the government has rubber stamped inappropriate sites by giving MACs, 45 yr. site occupation, with no EIAR or meaningful public participation. Example of Derrybrien bog burst in 2003 - wrong site selection and inadequate EIAR etc. 
> There are 11 iconic beaches and dunes at significant increased risk of future erosion if this project goes ahead. These include; Silver Strand, Magheramore, Magherabeg, Jacks Hole, Brittas Bay, Buckroney, Ennereilly, Clogga, Kilmichael, Kilpatrick and Kilgorman Strand. These locations are completely reliant on the continuing viability of the Arklow sandbank for their very existence.  
> Within this 22km there are diverse ecosystems centred around the estuaries, sandbanks and reefs. This is where the spawning grounds and nurseries live. Alongside the crab and shell species, they are the breeding grounds for herring, sand eel and mackerel. These fish feed numerous other fish species such as cod, bass, pollock, which in turn feed porpoise, dolphin and seals, right the way up to the fin and humpback whales that roam these waters. Wind farms placed within this 22 km stretch will devastate these ecosystems and the many people and communities that rely on the foreshore for their living. Beyond 22km the seabed is substantially less fertile.
> Technology has evolved significantly from 2004 when the Arklow Bank location was first selected by Airtricity and GE to build a 7-turbine "demonstrator project". We are now 20 years later, and SSE Renewables are world class leaders in offshore wind energy. SSE Renewables are currently shown as owning or being involved in three offshore wind farms in the UK, all located beyond 22km.  A marine geophysical survey for the Mac Lir Offshore Wind Farm, completed in 2023, has validated a site east of the Arklow Bank as being suitable for fixed-bottom turbine foundations. Home | Mac Lir Offshore Wind Farm

Conclusion: 

The 2020 Guidance document on wind energy developments and EU nature legislation indicates that the “best way to minimise negative effects on EU-protected habitats and species is to locate projects away from vulnerable habitats and species, (a practice known as ‘macro-siting’). This project has potential negative impacts on other countries, including Wales and England, for marine mammals and avian species.   

The Government has publicly stated that our total offshore wind target for 2040 includes the deep waters of the Atlantic Basin and its capacity to harness large quantities of wind energy. In 2020, the average distance to shore for offshore wind farms was 52 km and the water depth 44m.  

Admiralty charts show sea depths ranging from 37 metres to 58 metres over most of the seas east of the Arklow Bank with seabed reaching a depth of 65m as it comes very close to the midpoint dividing line between UK and Irish waters. There is no rational and scientific reason to develop a supersized wind farm on a conservation site, surrounded by areas of special protection, only 6 km from eleven sandy beaches.

The foreshore is a finite and valuable natural resource and public amenity. It is imperative and in the overriding interest of the Irish people and future generations that this proposed site is abandoned on the basis that a publicly available independent assessment of alternative sites east of the Arklow bank is undertaken as a matter of urgency to determine the existence of far less damaging solutions. 

It would be nothing short of a travesty if the government was to knowingly risk irreparable damage to the heart of what represents our sense of place and defines our identity - the rich ecology and seascapes of the Irish natural environment within the garden county of Ireland.  

This is an ill-conceived proposal which carries huge environmental risks and should be refused.