offshore wind farm

Offshore Wind Ireland – we have put together this comprehensive guide to give an overview of the common questions around wind turbines, distances to shore, visual impact and what is done in other countries.

Table of Contents

Why does your organisation exist?

Blue Horizon exists to advocate for proper marine spatial planning (MSP) and siting of offshore renewable energy (ORE) developments at least 22km from shore which will have no damaging effects on our marine environment or the welfare, economic prosperity and well-being of our communities.

Does Blue Horizon support the transition from fossil fuel to renewables, including offshore renewables?

Emphatically yes. It is absolutely clear that there is an imperative need to decarbonise our energy supply and that the development of renewable energy will be a critical step in this process. Given that we face major challenges due to climate change and biodiversity collapse, the need to re-think is both critical and urgent. We support the development of renewable energy when, in line with best international practice, sites are carefully selected to avoid the negative environmental and visual impacts associated with offshore wind and when proposed projects are subject to a modern democratic marine planning process, for example ecosystem-based Marine Spatial Planning.

What is marine spatial planning (MSP) and in what way would MSP help?

Marine spatial planning (MSP) is a process that brings together multiple users of the ocean to make informed and coordinated decisions about how to use marine resources sustainably. In a European context, MSP is defined as ‘a process by which the relevant Member State’s authorities analyse and organise human activities in marine areas to achieve ecological, economic and social objectives’ (EU, 2014). The European Union (EU) Maritime Spatial Planning Directive (2014) required all Member States with marine territories to prepare ecosystem-based maritime spatial plans for their waters by March 2021. According to Walsh (2023) MSP bears many similarities to land based urban and regional planning but, distinctively, has an ecosystem-based approach at its core and is underpinned by robust scientific data-gathering and analysis. This approach allows for maximising the benefits of our seas, while minimising the harm to our coastal seascapes and habitats in order to ensure that the common good is served.

What does ecosystem-based mean?

Ecosystem-based planning seeks to balance ecological, economic and social goals and objectives towards sustainable development. It further identifies and understands the important ecological characteristics of an area while underpinning the design of plans to guide the development of ecologically and socially responsible human activities in that space.

Ecosystem-based planning focuses on the diverse benefits provided by functioning marine ecosystems, rather than on single species, habitat or ecosystem service. An ecosystem-based approach ensures that the protected species, habitats and the unique ecosystems that support them are maintained. All such species/habitats are interconnected and cannot be considered independently. Benefits of proper ecosystem-based planning include vibrant commercial and recreational fisheries, biodiversity conservation, properly sited renewable energy from tidal, wind or wave sources and protection of our coastlines and seascapes from inappropriate development.

Although the current programme for government has set ambitious targets for offshore wind by 2030, there is a sense that the process of MSP is being rushed in order to achieve this in such a short time-frame. Acknowledging the urgency of attaining these targets, it is imperative that a precautionary, ecosystem-based approach to marine planning decision-making is adopted to avoid adverse impacts on the marine environment. Of the factors listed above, biodiversity conservation, inshore fisheries and the protection of our coastlines and seascapes are threatened by the development of current Irish Government plans for offshore wind development.

So, did Ireland prepare a Maritime Spatial Plan?

Ireland, like other EU countries, was obliged to prepare an ecosystem-based spatial plan by March 2021 but, unfortunately, the plan developed by Ireland does not comply with the EU MSP Directive.

The National Marine Planning Framework (NMPF) adopted by the Irish Government in May 2021 is not ecosystem-based. It provides a policy framework for marine planning but does not deliver a coherent spatial framework nor manage competing claims to maritime space. It does not include a forward-looking planning function focusing on the management of future spatial demands over the lifetime of the NMPF and lacks any zoning component or map of spatial priorities. While marine spatial plans produced by EU Member States to date vary significantly in their level of detail and role within national governance systems, it is in fact very unusual for a national-level MSP not to include explicit spatial priorities or zoning of marine areas (Walsh, 2023). The NMPF, therefore, failed to meet the core requirements of the EU MSP Directive and cannot be considered as a marine spatial plan.

What are DMAPs?

In December 2021 the Irish Government introduced new marine planning legislation in the form of the Maritime Planning Act (MAP) 2021. The Act provides for development in the maritime area and any changes being made to the use of the sea, seabed or any structure in the maritime area (MAP, 2021). Within the act, a new provision for the establishment of designated maritime area plans (DMAPs) is introduced. These maps or specified areas will set out detailed forward planning procedures/ spatial designations for a range of activities in the marine environment and will define the exact geographical area, outline clear objectives regarding the proposed usage and demonstrate how the map designation has been informed by an ecosystem based and data driven selection criteria. It is interesting to note that NMPF states that ‘this new system of spatial designation will provide for specific activities including offshore renewable energy (ORE) and emerging renewable technologies’ and doesn’t mention any other activities.

In July 2023 a south coast DMAP proposal was launched for public consultation (see below). The proposal features an area defined by the 80-meter contour depth and covers a significant portion of the Wexford, Waterford and Cork coastlines. The proposal will be refined in the coming months and the department of the Environment, Climate and communications (DECC) have indicated that they will take all stakeholder concerns on board in developing a DMAP within the proposal specifically for a 900 MW wind farm. The windfarm must be located on the south coast because the DECC (and government) have ruled out floating technology and are constrained by the fact that this is the only area which has grid availability to absorb the electricity generated from such a proposal. This immediately flies in the face of any proper marine spatial planning as it is far from an ecosystem approach in designating a site for ORE development.

In the coming months the Government intends to survey the proposed DMAP area and, from the collected data, will select several sites within the DMAP area which will be deemed suitable for ORE development and, from that, create a draft DMAP. After a further consultation period (early to mid-2024), a final DMAP will be presented to the Minister for Housing and both houses of the Oireachtas for approval. The water off our south coast within the boundaries of the proposed DMAP are quite shallow in relation to the rest of the Irish coastline and, considering available technology, it is possible to locate bottom fixed turbine foundations well beyond the 22km (12-mile territorial limit). There is the view that building closer to shore is a cheaper option and will give better value to Irish consumers but in recent years developers are moving further offshore to avail of better wind speeds and higher capacity factors which will, in turn, deliver cheaper electricity over the lifetime of a project. It remains to be seen what happens over the coming months and, although there were over 1400 individual responses from the Waterford public calling for any ORE developments be located at least 22km from the coast, we fully expect that Ireland’s first DMAP for offshore wind will be designated in a developer friendly zone close to the Waterford coast.

Regarding offshore wind development and EU best practice, where does Ireland fit in?

Regulation of offshore wind development varies throughout the world. This is sometimes justified with claims that the sector is nascent, i.e., emerging, and consequently some countries are only in the process of developing policy in relation to it.

Ireland’s offshore planning application process has recently (2023) changed from a developer led to a plan led regime. This now means that the Irish state will select sites most suitable for ORE development rather than individual developers which has been the case until now. This change aims to reduce speculative development (14 different proposals off Waterford) and move to a plan led regime where sites are designated by the state as DMAPs, thus aiming to satisfy the ecological, economic and social objectives of the NMPF and EU Maritime Spatial Planning Directive (2014). As of November 2023, Ireland’s first DMAP on the south coast is being considered by the DECC.

However, much of Ireland’s environmental law is grounded in long-standing EU laws and Directives which are applicable within individual Member States. This includes the Marine Strategy Framework Directive (2008/56/EC), the Birds Directive (2009/147/EC), the Habitats Directive (92/43/EEC), the Strategic Environmental Assessment Directive (2001/42/EC), the Environmental Impact Assessment Directive (2011/92/EU), and the EU Maritime Spatial Planning Directive (2014/89/EU). Ireland has continued to process applications for offshore wind without regard to a number of these Directives. This failure to comply with the Directives has resulted, on a number of occasions, in Ireland being found to be in breach of EU law, the most recent judgement against Ireland made on 30 June 2023.

Are you simply arguing for biodiversity protection because you don’t like the look of turbines off our coast?

No. While visual impact on our seascapes is a valid cause for concern, we also fear that important functioning marine and coastal ecosystems will be destroyed as a result of Ireland’s lax permitting regime for offshore wind. This, combined with the government’s inordinate delay in putting in place protection for marine habitats and species (Marine Protected Areas), and our awareness of how critically important it is to preserve and restore these ecosystems to avoid biodiversity loss and help to mitigate climate change, is why campaigns such as Blue horizon are so important. We are fully supportive of the development of offshore renewables when developments are appropriately sited and managed under a modern, democratic, ecosystem-based marine spatial planning regime.

What determines how close to the sea shore that a wind turbine can be located?

Turbine distance to shore tends to correlate with advances in technology and local coastal water depth. Ireland’s only offshore turbines, constructed over 20 years ago in Phase One of the Arklow Bank development, are located 10km from shore in approx. 5-10 meters  water depth and are 124 meters high.

In the early stages of offshore wind development, it was a huge accomplishment to sink a turbine foundation into 10 meters of water. This explains why some early developments in the UK and Europe are located in shallow water relatively close to shore. Advancements in technology now allow bottom fixed turbine foundations to be installed in up to 70 meters of water. Developers are already installing foundations at this depth and considering depths of up to 100 meters.

This, together with the introduction of floating turbine platforms, means that the majority of current EU and global offshore wind developments are located a minimum of 25 km from the shore. At this distance, higher wind speeds are accessed, capacity factors increased, and visual impact is significantly reduced. In Ireland, the government has imposed no restriction on proximity of wind farms to shore. For this reason, developers have targeted sites that are significantly closer to shore than would be permitted in other EU countries. In parts of our coastline where water depths, seabed and metocean conditions are suitable, there is no valid reason why Ireland’s offshore renewable energy developments should be placed so close to the shoreline other than to satisfy the demands of the wind industry lobby who represent inexperienced developers who lack the technical capability to deliver projects in deeper waters.

What are the offshore elements of a wind park?

A typical wind park using fixed bottom foundations consists of wind turbine generators, associated foundations, an offshore substation and associated foundations, cables linking each turbine to the substation (inter-array) and export cables which bring the power from the wind park to an onshore substation. Power is then transferred to the electricity grid for distribution to homes and businesses.

Components of an offshore windfarm

What is a wind turbine?

offshore wind turbine

A wind turbine consists of a tall cylindrical tower with a nacelle (generator housing) on top which contains the functional components of the turbine. Attached to the nacelle are three long blades which rotate, driven by the force of the wind. This energy is converted into rotational kinetic energy which is then used to generate an alternating current of electricity via rotating magnets inside a coil of conductive wire. For maximum efficiency, turbine nacelles rotate through 360 degrees in order to keep the blades facing into the wind. The specifications of turbines vary between manufacturers. Presently, the largest offshore turbines have an overall height from sea level to the blade tip of almost 300 meters (1000 feet). The turbine tower diameter is approximately 7-9 meters. Blade tips can reach speeds of 195 km/h when rotating. Generally speaking offshore turbines are placed approx one kilometer apart to ensure good airflow through each turbine. This will vary depending on individual turbine rotor height and diameter.

What are bottom-fixed wind turbine foundations?

In simple terms fixed bottom wind turbines are turbines that are individually anchored to the sea bed: some are anchored using a structure called a monopile, others are fixed with what’s called a jacket foundation. Monopiles are hollow steel cylindrical tubes approximately 8 meters in diameter with wall thicknesses of 8-10cm (imagine a really massive steel drinking straw). Using a hydraulic device monopiles are hammered down between 40-50 meters into the seabed. A turbine is then attached to the monopile via a transition piece. Each monopile requires thousands of tons of rock to protect the base from hydrodynamic erosion. Monopiles are ideally suited to shallower waters and have remained the preferred choice of most developers with almost 80% of all turbines installed across Europe using this foundation including Ireland’s only turbines located on the Arklow Bank. Water depth plays an import role regarding the use of monopile foundations and current advancements in manufacturing an installation allows this technology to be deployed in up to 60 meters depth. Seabed conditions will also dictate whether the pile can be driven deep onto the ocean floor. A significant drawback with monopile foundations is the increase in material required to deliver performance in deeper water and their potential impact on marine life from noise and vibration during installation and operation.

Jacket foundations are a lattice structure of steel tubes consisting of three or four legs and are normally attached to the seabed by fixing each leg to a pre-driven monopile. Again, thousands of tons of rock are required to protect the base of each leg from hydrodynamic erosion. The advantage of jackets foundations is their higher stability and better performance in harsh environments and deep water like we have on our Atlantic coasts. Research has demonstrated that jacket foundations become more economical than monopiles in water depths of over 45 meters. Currently, bottom-fixed turbines using jacket foundations, are being installed by developers in waters up to 80-90 meters deep.

Image showing different offshore turbine foundations

What is a floating wind turbine platform and does floating wind offer any benefits?

floating wind turbine

A floating wind turbine platform is anchored to the seabed and can carry a turbine in water depths of between 80-200+ meters. While fixed bottom wind turbines are limited to being sited in waters of approximately 70 meters deep, floating wind turbine platforms allow developers to use deep water locations where wind speeds are more reliable and stronger, visual impacts are less and environmental impacts on the seabed are likely to be minimised due to less invasive installation and operation phases.

Additional advantages of floating foundations are that they can be pre-assembled in Irish ports and then towed out to sea and fixed in position. Not only will this bring employments benefits to local business, it will also help build a strong indigenous supply chain and make Ireland a world leader in floating turbine technology. In comparison to the installation of a bottom fixed turbine (14% local content), a floating wind project can have up to 33% of the overall cost sourced from local business and port infrastructure (Cummins, 2023).

Although commercial scale floating windfarms will be operational worldwide by 2027/ 2028, the Irish Government has stated that it will not provide any route to market for floating wind before 2030, although Ireland is ideally positioned to become a world leader in the development and supply of this technology. This is even more concerning considering that approx. 85% of Ireland’s wind resources are in water depths of over 80 meters. No clear explanation has been given by the DECC for this decision, but sources suggest a narrow-minded view centered on short term bottom fixed projects in order to achieve lowest cost to the consumer.

How high are offshore wind turbines?

Turbine height graphicIreland’s only wind turbines currently in operation are situated on the Arklow Bank: these are sited approximately 10km from the seashore and were built in 2003. The height from the surface of the sea to the tip of the turbine blade is 124 meters (407 feet). Twenty years later turbine heights now extend to almost 320 meters from sea level to the turbine blade tip (1050 feet). It is difficult to imagine the scale of such a turbine, but if you have ever seen the Eiffel Tower in Paris, or can picture it in the Parisian skyline, you’re there: modern wind turbines are just four meters shorter than Gustav Eiffel’s tower! Closer to home, consider that the Dublin Spire is 121 meters tall: the same height as one blade on a modern turbine. Try imagining two Dublin Spires positioned lengthways to get an idea of the rotor diameter then add another 40-50 meters to allow for clearance of the water surface—that’s how big modern wind turbines are. Generally, people find it difficult to conceptualise the size and scale of modern turbines; that’s why we’ve created some infographics with some visual representations.

If you stand at the lifeguard’s hut in Tramore and look in a south easterly direction at Brownstown Head, you are observing the headland and twin towers at a distance of 4.1km. The image below represents the approximate height of offshore wind turbines which may be deployed along the Waterford coastline within the next 10 years. Although the turbines are aligned with Brownstown Head and Helvick Head for comparison, the likelihood is that they will be deployed further offshore but unfortunately, the forthcoming DMAP will most likely provide for turbines located well inside the 22km distance which Blue Horizon is campaigning for.

Using simple trigonometry and assuming that turbines of this size (and larger) will be used in any forthcoming developments, any turbines located a minimum distance of 22km off Tramore will appear as the exact height of Brownstown Head (55 meters high to the top of the towers). In our opinion this would be a significant impact on the coastal landscape and would never be tolerated in any of our coastal county development plans. Any turbines deployed inside 22km will appear significantly larger than the headlands and dominate the seascape. One can only cringe at the thought of turbines deployed at a distance of 10km or less from our coast; something which the Minister for the Environment (Eamon Ryan) has facilitated off the Dublin and Wicklow coastlines.

Unlike what some local politicians and commentators may say, turbines at 22km WILL NOT be hidden by the curvature of the earth and WILL BE HIGHLY visible from our coast so please use this analogy to press home the point that a 22km minimum distance to shore is NOT a big ask and, to reiterate, at 22km the turbines will be appear to be the same height as the Brownstown towers and appear even larger than Helvick Head once viewed from the same distance (4.1km)

Graphic of Turbines in relation to Tramore and Helvick Head

What about the visual impact of these developments? Will I be able to see them? 

Lincs offshore

Yes. Offshore wind developments currently proposed in Ireland consist on average of around 70-100 turbines per development. With turbines of approximately 250-300 meters tall, located 10-15 km from shore, these proposed developments would dominate the coastal landscape/seascape. International research suggests that wind turbines of this magnitude would need to be located approximately 45 km from shore before they become visually insignificant. At 10-15km from shore, turbines this scale will be the dominant feature within the coastal landscape. In Ireland it is currently being proposed that such enormous turbines could be sited 6-8 km from the Wicklow and Connemara coastlines.

The Irish coastline, which is so much part of our collective heritage and identity, remains relatively unspoilt and is of enormous value to the Irish people and visitors to the island. Ireland has an opportunity to adopt a measured, sustainable, innovative and environmentally sensitive approach to offshore renewable energy development, learning from those countries which have already adopted a variety of approaches, policies and technologies. We must argue robustly to protect Ireland’s magnificent coastal landscapes and those whose welfare and economic prosperity depends on preserving the visual integrity and unique quality of this environment.

What’s the problem with the projects that were successful in the government’s recent ORESS1 auction and awarded contracts from Eirgrid?

The Irish government continues to support a developer-led business model for Phase 1 of its offshore wind plans. This has allowed developers to identify and lay claim to any site they chose and applied for rights on that site. Currently, four projects have received a route to market (meaning that these projects have been accepted for the government Offshore Renewable Energy Support Scheme (ORESS1); North Dublin Array (off Skerries), Dublin Array (Kish & Bray Banks off South Dublin), Codling Wind Park (off Greystones) and Sceirde Rocks (off Connemara). 

These sites were targeted by speculative interests more than 20 years ago without any environmental assessment as to their suitability for development. Careful site selection is the most important step in avoiding damaging environmental impacts of wind and solar developments. These historic sites have not been the subject of any Strategic Environment Assessment (SEA), nor are they required to align with a marine spatial plan. The sites were proposed many years ago and have since progressed through the planning system largely protected from scrutiny under the description of ‘relevant projects’ by the Minister for the Environment.

The only environment assessments undertaken have been commissioned and paid for by the developers and environmental consultants employed by, or associated with, developers. This is, surprisingly, not illegal, but it underlines the importance of having a robust system to scrutinise submissions made in support of the developers’ proposals. In Ireland no such reliable system of scrutiny exists.

What is Strategic Environmental Assessment?

Strategic Environmental Assessment (SEA) is a process for the formal, systematic evaluation of the likely significant environmental effects of implementing a plan or programme, before a decision is made to adopt the plan or programme. The SEA Directive (2001/42/EC) requires that all plans and programmes that have the potential to have impacts on the environment are subject to SEA. However, in Ireland, certain plans and programmes have either not been subjected to SEA (Harnessing our Ocean Wealth – An Integrated Marine Plan for Ireland, 2012) or the Directive has been incompletely applied (Offshore Renewable Energy Development Plan, 2014).

Is electricity generated from wind energy sources cheap for consumers?

The quick answer is no. The illusion that electricity produced from renewable energy sources is cheap has yet to be proven. Two of the early adopters of renewable energy, Denmark and the UK, both have some of the highest consumer electricity prices in Europe at €0.60 kW/h compared to Ireland which currently averages at about €0.42 kW/h and way above the EU average of €0.28 kW/h. Considering that Denmark generates over 70% and the UK 41% of their electricity from renewable sources (mostly wind) it appears that renewable energy will not deliver the lower prices we had hoped for.

On the other hand, electricity should not necessarily be cheap and, though there are social issues to overcome, increasing consumer (and commercial) electricity prices is one of the most effective ways of reducing electricity consumption and as a result, climate impacts.

To cover the initially higher costs involved in generating from renewable sources in Ireland, projects are subsidised. Developers partake in a government Offshore Renewable Energy Support Scheme (ORESS), which guarantees them a fixed price for electricity for the duration of the project. Developers must place bids regarding their supply prices and generation capacity in an auction (ORESS 1) and, in theory at least, the cheapest bids are accepted. A strike (guaranteed) price is determined by Eirgrid and successful developers are then assured of a route to market and a guaranteed price for the electricity their development generates. The auction price is based on contracts for difference, which means if the wholesale (spot) price drops below the strike price, the government will top up the developers to the predetermined strike price. If the wholesale price goes above the strike price, the developers pay back the balance.

The arrangement gives developers and investors a safety net, ensuring there is no way projects will fail in terms of financial viability. Ireland’s first two onshore wind energy auctions struck a price of €75/MWh and €97/MWh respectively; more recently the price was €100/MWh, higher than the previous auction but not surprising due to supply chain costs and inflationary pressures. Our first offshore auction in early 2023 revealed a strike price of €86/MWh. This is quite expensive compared to current wholesale gas prices which are currently less than €40/MWh. This means that Ireland’s offshore renewable energy prices are almost twice times the price of gas (December 2023) and the cost to the Irish taxpayer will be enormous. While the price of gas can be volatile due to market speculation and reaction to global events, the war in Ukraine and Germany’s long-term dependence on Russian gas and oil drove gas prices to €340/MWh in August 2022. Gas prices have now recovered due to abundant LNG supplies and reduced consumption.

What determines the wholesale price of electricity?

Because electricity is a commodity that cannot be stored efficiently, supply and demand needs to be matched at all times. Electricity generated from renewable sources such as wind and solar must be used immediately so it is fossil fuels such as coal, oil and gas which are engaged to balance grid demand. As wind and solar do not consume any materials in the production of energy, they are the first sources used to supply the grid. As demand increases, fossil fuels are added according to how expensive it is to obtain electricity from that source. This hierarchy, where the addition of progressively more expensive fossil fuel powered generators are added to supply the demand, is known as the merit order.

Wholesale electricity prices are calculated on a half hourly basis and are dependent on demand; this is referred to as the spot market price. The spot price is determined by the last source of electricity to enter the grid (or to ‘come online’) which is normally a fossil fuel such as oil or gas. Therefore, no matter how much renewable electricity is generated, the wholesale market price is determined by the price of the last generator to come online. The initial spike in gas prices in August 2022 resulted in significant price increases, which are beginning to recover. Energy company hedging strategies kept prices artificially inflated in Ireland for almost 14 months after the spike. Given current wholesale market prices for natural gas, currently below €40/MWh (December 2023) renewable energy is one of the most expensive generation sources to supply electricity in Ireland.

How do Irish offshore electricity prices compare with those in the UK?

Badly. The last offshore wind auction (Round 4) in the UK resulted in a strike price of around €40/MWh, which is less than half of what Ireland recently achieved. The locations selected by the UK government for offshore wind were in areas approximately 45 km from shore and, in some cases, up to 135 km from shore. These projects would have incurred higher capital expenditure costs due to the distance from shore, so the lower strike price achieved by the UK government is even more impressive. It is important to remember that the UK mainland is less than 100 km from Ireland and the same energy companies are involved. So why is Ireland’s offshore renewable energy so expensive?

The four Irish projects awarded contracts from Eirgrid are located approximately 10 km from shore, on shallow Annex 1 sandbanks and inshore fishing grounds. These locations should represent the cheapest option for developers, begging the question as to why the Irish offshore electricity strike price from ORESS1 is so expensive, at €86/MWh.

In recent times the UK has encountered the reality of offshore wind rising prices. In it’s Round 5 energy auction, where the UK Government placed a maximum price cap of £44 MW/h, no developer bid. Swedish developer, Vattenfall, also dropped plans for a huge offshore windfarm off the UK’s Norfolk coast because rising costs meant it was no longer profitable. This meant that the UK made no increases to its renewable energy pipeline, although up to 5 GW was available. In November 2023, following concerns from developers regarding rising costs, the UK Government has increased its maximum price from £44 MW/h to 73 MW/h for its Round 6 auction representing a 66% increase. This can only be bad news for the consumer and illustrates the rising cost of offshore wind. It is widely speculated and reported from within industry that developers here, who were awarded contracts at €86 MW/h, will not be able to proceed at that price and remains to be seen what the next move will be.

How will electricity generated from offshore wind be used?

This is a complex question for which there is no clear answer. We do know that the Irish grid needs enough electricity to cover a maximum demand of approx. 5.5GW. Renewable energy sources already supply approx. 35% so there is a shortfall of approx. 3.5GW to satisfy maximum grid demand from renewable sources. What is known is that the increase in demand for energy from data centres puts a disproportionate and increasing burden on Ireland’s energy supply. While it is likely that some energy generated from offshore wind would be fed into the grid, current government policy includes plans to further increase the number of data centers the country will host, leading to a concomitant increase in energy demand.

Data centres are a high energy demanding industry, providing relatively little employment. A recent webinar hosted by Friends of the Earth, Ireland, provides very useful insight into the inadvisability of Ireland’s current data centre policy, and appeals for a re-think. A case in point is the current situation in Arklow.

The current promoters of the proposed Arklow Bank development, SSE, are aiming to construct 197m high turbines about 6 km from Brittas Bay and the Wicklow coast, in close proximity to Wicklow reef, (the first example of a subtidal sabellaria alveolata reef in Britain and Ireland), Wicklow Head SPA (a protected area for IUCN red listed Kittiwakes) and adjacent to the Buckroney-Brittas Dunes and Fen SAC, which hosts unique priority habitats, protected under the Habitats Directive.

Although this proposed project is very much in the early stages of planning, SSE appear to have already entered into an agreement to supply the energy generated to an Echelon Data Centre, and apparently further such agreements are envisaged. That this agreement has been reached in advance of the Arklow proposal even making an application for planning permission, raises serious questions about the planned use of Ireland’s offshore renewable energy. In addition, and perhaps of even greater concern, is that it creates serious doubt about the objectivity and impartiality of the planning and environmental assessment processes being put in place to manage wind farm applications. Though we recognise the urgent need for renewable energy, this should not be achieved at the expense of our marine environment in order to provide energy for data centres.

How are offshore renewable energy (ORE) sites selected in Ireland and the UK?

In the UK, the Crown Estate (a commercial business independent to UK government but which pays income from the management of the estate to the UK Treasury) is responsible for managing the seabed and facilitating competing demands for space from different industry sectors such as the wind energy development sector which seeks to locate wind parks and associated cabling and pipelines within Crown Estate lands. The Crown Estate ensures that legislation such as, for example those relating to habitats and birds, is adhered to in order to protect sites within the Crown Estate from adverse impacts of commercial activity. The Crown Estate assesses whether projects proposed for development are suitable for the sites suggested and determines whether legislative directives are satisfied before rights to develop are granted. For example, the Habitats Regulation Assessment (HRA) must be conducted before seabed rights are awarded to wind park developers in the UK. The support of relevant planning authorities and nature conservation bodies may also contribute to the final decision made by the Crown Estate. The Crown Estate asserts that its independence from government is critical to creating environmental, social and financial value for the people of the UK.
In Ireland, the first offshore marine area consents were awarded to seven offshore renewable energy projects in December 2022 by the Minister for the Environment. The seabed consents were given to legacy projects which were self-selected by developers. These sites were never subject to a strategic environmental assessment (EU SEA directive) and were located on sensitive sandbanks and fishing grounds which had previously been proposed as special areas of conservation (SAC) under the EU Habitats Directive. The awarding of marine area consents (MAC) in Ireland contravenes good marine spatial planning and breaches the EU Strategic Environmental Assessment, Habitats and Birds directives.
The Marine Regulatory Authority (MARA) was established in July 2023 and is the new state agency for the awarding of consents, licencing and enforcement of Ireland’s inshore and EEZ marine space. At the time of writing, no consents or licenses have been issued by the new authority regarding any ORE projects.

Offshore wind Ireland: Why are Ireland’s wind parks located so close to shore?

Irish wind parks are located close to shore because they are located on sites that were selected by developers many years ago. From a cost perspective, turbines that are located in shallow water and close to shore require fewer materials in the foundations and shorter cable lengths to deliver the power to onshore substations. While this may be advantageous to the developers, poorly sited wind parks will potentially have devastating consequences for marine biodiversity, and inshore fishers while also resulting in the industrialisation of shorelines and seascapes. Although several early wind parks in the UK and Europe, including the current Arklow Bank turbines, were situated closer to shore due to technological restrictions, current wind parks are now typically sited in excess of 25km from the shore with some wind park developments located as far offshore as 135km. Because of a lack of proper ecosystem marine spatial planning and strategic environmental assessment, Ireland is the only country in Europe facilitating the siting of large turbines so close to shore. 

The wind industry maintains that ORE projects can have a positive impact on ecosystems and that using rock armour will create artificial reefs around turbine bases that will encourage/ increase new marine life. Is this true?

No, there is no reliable evidence to support this claim. Bottom fixed wind turbines require thousands of tons of rock (described as rock armour) to be dumped around the base of the foundation. The rock is necessary to protect the turbine base and surrounding seabed from erosion caused by water movement. The amount of rock armour required for one typical monopile turbine foundation is enough to completely fill four average-sized two-story houses.

An early study (2015) on small offshore wind turbine foundations suggested an increase in the variety of species present close to the turbine bases due to the introduction of hard substrata (rocks and concrete) around the bases. The study also noted that the increase in species diversification may have been as a result of commercial fishing ceasing within the wind farm areas. It is known from a recently published long-term study carried out in Belgium that impacts change over time. After a ten-year period of monitoring, while initially it looked as if there might be some positive changes, the authors reported ‘slimeification’ and decline of the initial invasive species, effectively leading to significant deterioration of the original ecosystem. The study concludes that earlier reports on offshore wind turbines as potential biodiversity hotspots should be considered premature.

In short, turbines and hard substrata do not belong in functioning, high biodiversity, sandy or soft mud ecosystems. Hard structures such as these facilitate the development and proliferation of different and potentially invasive species that will out-compete native species resulting in reduced biodiversity.

The recently published seabirds count survey (2023) has indicated that there is a decline in our Puffin and Kittiwake populations. One of the key reasons for their decline has been identified as a shortage of food during the breeding season. The declining availability of sand eels and sprats is most likely as a result of commercial fisheries, but an interesting fact is that sand eels, on which endangered bird species feed, require sand to survive and reproduce? Construction of windfarms on sandbanks would require the removal of 3-6 metres depth of sand, destroying this important sandy habitat. The International Union for the Conservation of Nature (IUCN) Red-listed Puffin and Kittiwake feed almost exclusively on sand eel, which means construction of wind farms on sandbanks has a direct impact on a declining species already protected under the EU Birds and Habitats Directive.

How many offshore wind developments are being proposed in Irish waters?

Up to March 2023 the Irish Government encouraged a developer-led approach for offshore renewable energy projects leading to approximately 70 applications in various locations around our coast. This approach meant that developers could pick and choose potential windfarm sites in the absence of any form of zoning or spatial planning in the maritime area. However, a policy shift announced in March determined that windfarm projects would be now developed via a new planning process involving windfarm developers competing for permission to build on offshore sites pre-selected by the Government.

The selection of DMAP sites, within which developers then compete for permission to construct, should be determined by an ecosystem-based process. Unfortunately, in Ireland, ecosystem considerations do not appear to have influenced the DMAP site selection process. Instead, grid constraints and economic considerations have influenced the DMAP selection process; focusing on high biodiversity value sites already targeted by developers, thus making a nonsense of the idea that Ireland is espousing a plan-led approach.

Nonetheless, the decision to create DMAPs is Ireland’s first attempt at maritime spatial planning with regard to offshore wind energy development and, undoubtedly, is a welcome step because, in theory at least, it means that there is a commitment to a State-led planning approach to identify specific sites suitable for offshore renewable energy production.

Developed by the newly established Marine Area Regulatory Authority (MARA), Ireland’s first DMAP includes areas off Waterford, Wexford and Cork. Further DMAPs are planned for designation along our east coast, again an area where international energy companies have already targeted vast areas of the coastal zone for offshore renewable development.

Are you simply arguing to protect biodiversity to reject the development of wind parks?

What is visible above the water is only the tip of the iceberg with respect to wind parks. Most people think the seabed around our coast consists of sand but in fact, it consists of so much more, with rocky terrains and glacial deeps, biogenic and geogenic reefs hosting a huge diversity of life forms. In fact, our seas and sea beds host our least spoiled functioning ecosystems. Such ecosystems constitute a massively valuable carbon sink and many are the only remaining fish spawning habitats in Irish waters. Many of the planned wind parks are sited within special areas of conservation for sensitive cetacean species like the harbour porpoise and adjacent to Special Protected Areas (SPA), designated for rare sea bird species like terns and kittiwakes. 

The noise produced during investigations, construction and operation of wind parks causes permanent and cumulative damage to the hearing of harbour porpoises. Porpoises use their hearing to navigate, hunt and mate so porpoises with damaged hearing often die. In the German North Sea, the harbour porpoise population has drastically decreased after the development of wind parks there. It may be that some porpoises migrated because the harbour porpoise population grew elsewhere but habitat erosion caused by poorly located wind parks will result in biodiversity loss and death of marine life. The size and scale of turbine arrangements within large wind parks have the potential to act as a barrier to the migration of birds and marine mammals as is currently happening along the east coast of the USA where an increase in whale deaths is reported. The only change to that habitat is the recent development of ORE and associated activities. This biodiversity damage is untold and may never be recoverable. Poorly sited wind parks will kill existing bird and marine life, destroy habitats and prevent migration. This damage is already happening but, while offshore wind parks will have an environmental impact that is not without damage to the environment, such parks can be designed and located in ways that respect and protect the habitats and marine life that currently occupy and live within these sites.

If ORE projects are given planning permission in ecologically sensitive areas, what do we have to lose?

Everything. Our marine ecosystems are dependent on the food web which starts with the phytoplankton. These are the key to everything. If we demolish these EVERYTHING else dies. Additionally, the oceans’ ecosystems provide approximately 50% of global oxygen: marine ecosystems are vital, right down to the air we breathe. Areas containing natural reefs, seagrass and sea-pens capture carbon from the atmosphere and are incredibly effective. For example, seagrass beds capture carbon 35 times faster than a rainforest. It is ironic that Europeans often loudly condemn the Brazilian government for allowing the demolition of rain forests while at the very same time facilitating industrial development in European oceans that pose significantly greater, in fact catastrophic, environmental damage. We need these areas to capture carbon, not for decades or centuries but for millennia.

Reefs give life to our seas providing shallow light filled waters for phytoplankton to bloom, fish to spawn, sharks and whales to feed. The most effective carbon sink of all is LIFE! Once an area becomes a dead zone it is incredibly difficult to restore life: this reality is evidenced in the challenges faced by marine biologists and ecologists in terms of the difficulty and oftentimes failure to restore oyster beds following habitat destruction. The consequence of failure is bleak. Hope lies in ORE planning that is based on careful, respectful and knowledgeable decision making designed and implemented to create and deliver an ORE strategy that preserves, protects and promotes environmental, social and financial value. This strategy will yield results both now and in the long term. We must urge our politicians, civil servants, the wind industry and our communities that locating wind parks outside shallow, near shore, high biodiversity areas will result in the creation of abundant energy generated in ways that will best conserve our delicate unspoilt ecosystems.

Up to March 2023, the Irish government has allowed commercial interest to dictate the locations of Irish wind parks and those same politicians seem content to assume that the wind industry will regulate itself. As we know, to our cost in Ireland, commercial sectors are notoriously incompetent in relation to self-regulation: waiting for effective self-regulation within the wind industry will create a global debt that will take generations to return and may be impossible to repay. Recent initiatives to remedy the consequences of unregulated construction during the Celtic Tiger era will, unless the current approach is remedied, be replicated again except this time the damage will be to the marine environment and will directly contribute to potentially catastrophic climate and environmental destruction. Our elected representatives are poorly informed – we want to help them be better informed and get ORE development right.

In areas such as the Irish Sea and Ireland’s south coast where strong tidal flows prevail, would the presence of multiple large structures in the water affect current flows, turbulence, mixing, sediment transport and biological activity in the immediate areas?

Yes. Several studies have indicated the possibility of negative impacts on marine life and marine habitat due to wake formation from turbines located in moving water. Additional sediment in the wake could cause a decrease in underwater light availability, negatively impacting primary production (e.g., phytoplankton survival and growth) and reducing the ability of sight-feeding predators to hunt their prey. It is also suggested that shifts in the patterns of suspended sediment will lead to changes in deposition or erosion patterns, risking reef smothering and increased erosion along Ireland’s coasts.

In particular, a 2018 study prepared for the Crown Estate (UK) identifies an increase of 40% in the concentration of suspended material in the wake behind monopile structures in an area where tidal flows were evident and further investigated several factors which would possibly cause increased sediment in the water. The study concluded that, along with scouring of the local seabed and the release of mud and organic material associated with epifauna (animals found to be living on or attached to the seafloor or submerged structures), the redistribution of suspended material from the lower water column to the surface is caused by the increased turbulence within the wake.

Research conducted in the North Sea (2019) also suggests that wind driven ocean circulation can be negatively affected because of reduced wind speeds in the lee of a turbine. The difference in wind speeds can singularly affect the circulation process but when combined with increased turbulence from tidal action, the mixing of sediments from different layers of the water column can be substantial.

Local evidence of shifting sediments as a result of wind turbine foundations in fast moving tidal waters exists. The seven Arklow Bank turbines sit on monopile foundations. In 2017, Arklow Energy Limited, the company who managed the development, were granted a Dumping at Sea Licence for use of a sea plough to dredge 99,999 tonnes of material that had accumulated around the bases of turbines. The permit was granted for a period of eight years, with no environmental assessment. The presence of the turbine foundations is directly responsible for such an accumulation of material on the Arklow Bank.

What about the significant community benefit funds involved?

Community benefit funds are generated as a result of developers partaking in the government’s Offshore Renewable Energy Support Scheme (ORESS). ORESS is an auction-based system designed to guarantee developers a fixed price for their generated electricity over the lifetime of the project. In turn developers are obliged to donate (to the community?) €2 for every MW/hour they generate which may amount to approximately €2-4 million in contributions per year based on a development of the size that is proposed on the Irish coastline. This is a sizeable amount of money for communities but remember the guaranteed price paid to wind operators comes from the public purse and from us, the customers. The ‘community benefit’ funds must be paid to communities regardless of how near or far from the coast a wind farm is located.

Additionally, successful projects will be paid for electricity they generate even if the grid cannot accept the load. This may happen in times of high winds and low demand. In this case, the taxpayer will pay for electricity that is not being used.

What’s wrong with building wind parks on sandbanks?

A – Sandbanks are important conservation sites because they provide vital nursery habitats for fish and key feeding and resting grounds for sea birds. Offshore wind turbine foundations have a significant impact and seriously detrimental effect on the composition of sandbanks. Sandbanks, particularly those located in the Irish Sea between Dublin and Wexford, are marine habitats situated in shallow water and listed as protected under Annex 1 of the EU Habitats Directive and are protected because they provide a buffer for beaches and dunes against wave action and tidal flows. Since Arklow Energy Ltd. sited 7 turbines on the Arklow Bank sandbank sand and silt has accumulated around the turbines to such a degree that maintenance boats were, at times, unable to gain access to the turbines.  The licence for the Arklow Bank wind park development was granted without an environmental impact assessment!

Offshore Wind Ireland: Will turbines affect bird species?

A – According to Birdwatch Ireland, over 95% of breeding seabirds are listed on the International Union for Conservation of Nature’s (IUCN) Red and Amber list of threatened species. Birdwatch Ireland is particularly concerned about the effect that offshore wind parks will have in terms of:

  • Collision morbidity – birds colliding with the rotor blades, towers nacelles and other infrastructure.
  • Disturbance and displacement – particularly during the construction and operation of offshore wind parks where birds avoid an area due to noise or visual intrusion.
  • Barrier effect – wind parks increase will energy expenditure by seabirds which will have to fly further to avoid parks. Raising a bird’s energy expenditure decreases its chance of survival on migration and its ability to successfully feed chicks during the breeding season.
  • Habitat loss or damage – the presence of wind park infrastructure within the feeding area of a seabird population will have a significant detrimental impact. Wind park infrastructure and operation could also affect the movement and navigation of other marine species including species of fish, crabs and shellfish that are sensitive to electro or magnetic fields.

Why should Ireland proceed with caution regarding the rollout of offshore renewable energy?

The biodiversity disaster in Derrybrien, Co. Galway exemplifies what can go horribly wrong when wind park developers and the Irish government disregard best practice, robust environmental assessment and European law. In 2003, during the construction of a 70-turbine wind park in Derrybrien, a landslide occurred causing over 450,000 cubic metres of peat to slide into the Owendalulleegh River: the result was the death of 50,000 fish. The European Court of Justice subsequently ruled in 2008 that an environmental impact assessment should have been conducted before the development was given permission to proceed. The park has since been decommissioned and the State has paid over €18 million in fines for failing to comply with EU legislation which resulted in this environmental disaster, with such serious consequences for the local community.

None of what the Minister for the Environment describes as Phase 1 ‘relevant projects’, i.e. wind farms that have been granted MACs and subsequent grid connections located in the Irish Sea and off the Connemara coast, were subjected to a strategic environmental assessment (SEA). This bears repeating: none of the wind park projects currently designated as ‘relevant’ by the Minister for Environment, Climate, Communications were subjected to a strategic environmental assessment. Difficult though it is to believe, this is the case.

It seems hard to believe that multi-million Euro wind energy projects that would involve construction of massive under and over water infrastructure in sensitive and protected inshore areas have been allowed to progress without comprehensive Strategic Environmental Assessment? Is this really the case?

Yes. A Strategic Environmental Assessment (SEA) was undertaken pre-2010 when Ireland’s draft Offshore Renewable Energy Development Plan (OREDP 1) was published. However, while the plan was criticised for the acknowledged data and knowledge gaps, more critically, the Environmental Report of the SEA revealed that “a Parliamentary Statement, provided by Eamon Ryan, Minister of DCENR confirmed that the SEA should not influence or affect the processing of existing Foreshore Lease applications”. This Parliamentary Statement resulted in legacy applications being excluded from SEA and instead being categorised as ‘already existing renewable infrastructure’. Clearly the projects in question were not already existing infrastructure.
The OREDP 11 has appeared in draft format (2023). The original OREDP 1 has been fully reviewed and a new SEA carried out in 2020, but since the consultation report on the draft plan has only been published in November 2023, the final OREDP 11 plan remains to be seen. Considering this, it remains that none of the currently proposed ORE applications have been subject to mandatory SEA and therefore contravenes the EU SEA directive (2001/42/EC).

So what is Blue Horizon asking for?

Blue Horizon asks for proper marine spatial planning (MSP) and siting of offshore renewable energy (ORE) developments at least 22km form shore which will have no damaging effects on our marine environment or people’s wellbeing. Up to March 2023, the Irish Government supported a developer led approach to renewable energy development in the maritime area resulting in almost 70 individual proposals in various locations around our coastline. As a result, all ORE projects currently in development within Irish jurisdiction are self-selected by developers having scant regard to environmental or visual impacts on the Irish coastline. Now that there is a new plan led regime in place, we hope that future developments will be selected using proper ecosystem based marine spatial planning while using technology and techniques which are aligned with international best practice.

We also advocate for the support of floating wind foundations around the Irish coastline. We note that the Department of Environment, Climate and Communications (DECC) aligns with a common excuse for not using floating foundations in that they have not been deployed on a major commercial scale to date although it is also acknowledged that a number of demonstration sites are in operation. We would make the point that floating technology is more expensive than fixed bottom at present but, without support from government regarding the development of local supply chain, ports, support vessels etc., floating wind will never become viable in Ireland. Acknowledging that over 80% of our wind resources lie in over 80 meters of water depth, this is too big an opportunity to miss. Floating wind is being developed in many other countries with commercial projects due to power up by 2027/ 2028/ 2029. Ireland will of course benefit from economies of scale in the long run but unfortunately most of the infrastructure will come from elsewhere and we will only watch as it floats by and on to a destination somewhere in the Atlantic. Although the government has committed to supporting floating wind technology sometime before 2030 (Policy Statement on the Framework for Phase Two Offshore Wind March 2023), failing to include for consideration in the South Coast DMAP proposal demonstrates a serious lack of ambition within the DECC.


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