Mr. Daryl Kennedy:

Thank you. I very much appreciate the opportunity to address the Joint Committee on the Environment, Culture and the Gaeltacht on the significant community concerns we have about industrial wind farm developments in the midlands. Mr. Andrew Duncan has just been introduced. He is from a solicitor's firm which goes back to 1918. Dr. Chris Hanning is an honorary consultant in sleep disorders to the University Hospitals of Leicester NHS trust in the UK. Mr. Dick Bowdler is an acoustic consultant and is also part of a working group that reports to the British Government on noise. He has been involved with acoustics since 1977. Ms Nora Fagan is a solicitor in commercial law from Westmeath.

I will go through the background and set the context of our concerns. Essentially, there is a proposal to develop a wind farm in the Irish midlands generating 8,000 MW of energy for export to the UK to help meet its binding 2020 renewable energy targets. Mainstream Renewable Power, via the Energy Bridge project, intends to develop 5,000 MW of generation using 500-ft. turbines, while Element Power, via the Greenwire project, intends to develop 3,000 MW of generation using 600-ft. turbines. These developments alone would mean that up to 2,400 industrial turbines would be placed through the Irish midlands. That is subject to an intergovernmental agreement in quarter one and also to the completion of a strategic environmental assessment, SEA, as part of the national policy context.

The intention is to submit planning applications in late 2014, based on SEA completion, and to commence development on approval. The developments are proposed for a mix of mostly open flat farmland, some forested areas and peatland. The current proposal includes development in areas with significant residential rural populations. They are core to the concerns we bring to the committee. If the proposals go ahead many communities will be surrounded by clusters of wind farms, with turbines allowed to be situated 500 m from a resident's front door or back door.

We represent the majority view in Ireland, which favours renewable energy. We are not anti-wind energy. We consider ourselves to be rational and objective people who have had to work tirelessly to extract information and disseminate it to our communities in the absence of formal consultation. This has cost us countless hours when we should be getting on with family life instead of having to work on this.

We reject the slur of the energy development companies, which described citizens who were concerned about proposals to place more than 2,500 turbines for domestic supply and export in the midlands as NIMBYs. Such a project represents significantly more than backyard development. However, we recognise with a strong degree of positivity the comments by the Minister for Communications, Energy and Natural Resources at the IWEA conference last week when he acknowledged the concerns of the community, which was hugely beneficial, and mentioned the unthinking communication by some developers. We also welcome his view that there will be a preponderance of wind turbines clustered on State lands far removed from people's homes. This is the core of our presentation, which is a vision of responsible development that we want transformed into a formal policy underpinned by clear and unambiguous guidelines and appropriate legislation aligned with various directives.

The hard-pressed communities of the midlands have only become aware of the proposed developments through newspaper articles and word of mouth over the past six to nine months and certainly not through formal consultation with a responsible Department or the energy companies. Token lip service has been paid to a form of consultation but it has been one-way, with limited information given to communities. This is despite the fact that most of the landowners who are required to sign up to the option contracts have done so. Approximately 1,000 landowners were signed up before communities became aware of what was happening. In the midlands, approximately 35 community groups have sprung up over the past six to nine months, at a rate of one group every ten days, as people have become aware of the proposed developments. We find that as each community becomes aware and people start to drill down into the issues, as Mr. Duncan, myself and others have done, they begin to realise that the proposals will have a cascade of consequences. We have brought experts with us to review the impact of these consequences, including on noise, health and property values, as well as other legal concerns. If time permits, we can provide examples of misleading information that has been given to communities and of the clear lack of information provided by developers. We can also provide numerous examples of division in the community, which is being caused left, right and centre by these proposals. Even as recently as yesterday evening, I got a call from a landowner living several miles away who would not give his name but who said the proposals were ripping his family apart. It was difficult to listen such a stressful account of what is happening.

We welcome the revision of the 2006 wind energy guidelines, as they were significantly out of date when first implemented. We have three significant concerns. The first is that this is just a targeted review examining shadow flicker, noise impact and separation distance. A tendered study by the SEAI will consider noise impact, but this is a desktop study, which is wholly inappropriate given the anecdotal evidence around the country. Some field studies should at least be done, with appropriately qualified people visiting those areas. A desktop study would be weak. Mr. Bowdler will go into this in more detail as he has made a submission to the 2006 guidelines review.

The second concern is that a number of items are not included in the guidelines, and because of the targeted review they will still not be included. I refer to article 3 of the 1985 environmental assessment directive, which deals with the assessment of impact on material assets and on health. That is not covered at all. One element that is included in the review is landscape, which is dealt with in Chapter 6 of the guidelines. This is our third concern. The chapter is specific and states: "It is important that wind energy development [...] is never perceived to visually dominate." On that basis alone, developers would not be coming in on top of our communities to build these turbines in residential areas. They would stay where they like to say they belong, which is in the distant background - on mountain ridges, etc. - rather than in residential communities, as facilitated by the current guidelines, with a separation distance of 500 metres.

While reference is made to a balanced, responsible and democratic approach, I draw the committee's attention to what is currently in train in County Westmeath, where almost 900 submissions were made to the 2014 county development plan, the majority of which related to wind turbine and industrial wind development. Consequently, the final draft of the plan strictly directs industrial wind development to cutaway bogs and appropriate and responsible step-back distances from people's homes.

We ask the committee to support a number of key actions that the Government should take: to provide of a clear timetable for the development of the strategic environmental assessment; to complete a comprehensive review of the 2006 wind energy guidelines, taking into account the issues I raised; to ensure the 2012 draft guidelines on environmental impact assessment and the 2002 EIS guidelines for developers are fully updated and in compliance with Article 3 of the EIA directive; to impose a moratorium until full and comprehensive compliance with the Aarhus Convention is ensured; to enact the Environment and Public Health (Wind Turbines) Bill 2012; and to provide an amnesty for farmers who wish to withdraw from the wind farm contracts they signed where they have not sought sufficient and independent legal advice.

Communities in Ireland and, in particular, in the midlands, feel they are being besieged by aggressive wind farm developers who are exploiting weak and outdated guidelines as well as the lack of specific legislation to govern wind energy development. The majority of people support renewable energy development, but it must be done responsibly, transparently and to the mutual benefit of all stakeholders, with affected host communities to the fore.