strategic environmental assessment and · strategic environmental assessment (sea), to determine...

Appendix 1 Draft Tipperary Renewable Energy Strategy

Volume 2

STRATEGIC ENVIRONMENTAL ASSESSMENT

AND

ENVIRONMENTAL REPORT

[APPENDIX 1] Volume 2

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Contents

1.0 SEA Introduction and Background ............................................................................... ...................4

1.1 Introduction ...................................................................................................................................... 4

1.2 The Tipperary Renewable Energy Strategy 2016 ............................................................................. 5

1.3 Relationship with other plans or programmes ................................................................................. 6

2.0 SEA Methodology .............................................................................................................................. 6

3.0 Summary of the Baseline Environment .......................................................................................... 8

3.1 Introduction ...................................................................................................................................... 8

3.2 Likely evolution of the environment in the absence of a new Strategy ........................................... 8

3.3 Biodiversity, Flora & Fauna ............................................................................................................. 8

3.3.1 Natura 2000 sites..................................................................................................................... 9

3.3.2 Natural Heritage Areas ............................................................................................................ 9

3.3.3 Landcover mapping ............................................................................................................... 10

3.3.4 Existing Problems .................................................................................................................. 10

3.4 Geology & Soils ............................................................................................................................. 14

3.4.1 Geology ................................................................................................................................. 14

3.4.2 Soils ....................................................................................................................................... 14


3.5 Material Assets .............................................................................................................................. 17


3.6 Cultural Heritage ............................................................................................................................ 17


3.7 Population & Human Health .......................................................................................................... 19

3.8 Air/Climate Factors ........................................................................................................................ 19

3.9 Landscape ..................................................................................................................................... 20


3.10 Water ............................................................................................................................................. 23

3.10.1 Water Framework Directive .................................................................................................. 23

3.10.2 Status of Surface Waters ....................................................................................................... 24

3.10.3 Status of Ground Waters ....................................................................................................... 24


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3.10.4 Registers of Protected Areas ................................................................................................. 24

3.10.5 Flooding ................................................................................................................................. 25


4.0 SEA Objectives and Indicators ...................................................................................................... 26

4.1 Strategic Environmental Objectives (SEOs) .................................................................................. 26

4.2 Development Objectives ................................................................................................................ 27

4.3 Consultation with Statutory Environmental Authorities. ................................................................ 28

4.3.1 Conclusion ............................................................................................................................. 30

5.0 Alternatives ..................................................................................................................................... 31

5.1 Evaluation of Alternatives .............................................................................................................. 32

5.2 Selected Alternative ....................................................................................................................... 32

6.0 Potential for Impact on the SEO’s ................................................................................................ 34

7.0 Incorporation of mitigation measures .......................................................................................... 39

8.0 Monitoring Proposals ..................................................................................................................... 44

8.1 Introduction .................................................................................................................................... 44

8.2 Monitoring for the Renewable Energy Strategy ............................................................................. 44

Appendix 1: Non-Technical Summary ....................................................................................................... 51


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1.0 SEA Introduction and Background

1.1 Introduction

The Draft Renewable Energy Strategy for Tipperary has been prepared to provide a county-wide planning

framework for Renewable Energy Development in County Tipperary. The Renewable Energy Strategy will

be incorporated by way of two variation processes:

Variation No. 3 of the North Tipperary County Development Plan 2010 (as varied)

Variation No. 3 of the South Tipperary County Development Plan 2009 (as varied)

The County Development Plan areas are illustrated below.

Figure 1: Plan areas of the Tipperary County Development Plans (as varied)


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Pursuant to the Planning and Development Act 2000 (as amended), the Council is required to undertake a

Strategic Environmental Assessment (SEA), to determine the likely significant environmental effects of

implementing a plan or programme before a decision is made to adopt the plan or programme. This

Environmental Report and SEA has been prepared in respect of Variation no. 3 in compliance with the

requirements set out under the Act. In this regard, it should be noted, that given the county-wide scope

and nature of the Renewable Energy Strategy, the Council has considered collectively and individually (as

appropriate) the impacts of the proposed Variations to both Development Plans. Therefore, this SEA will

provide a consistent assessment across the existing Development Plan areas. For clarity, all maps and

illustrations contained in the report, defines both Development Plan areas. This approach has been taken

for the SEA prepared in respect to of the Wind Energy Strategy - Appendix 2 and the Appropriate

Assessment prepared for the Renewable Energy Strategy and Wind Energy Strategy - Appendix 3 and 4.

The Renewable Energy Strategy sets out a vision for the positive development of renewable energy in

Tipperary, the vision is set out in Section 1.2 of the Renewable Energy Strategy.

The Renewable Energy Strategy was underpinned by an independent review of the wind energy polices of

the County Development Plan (as varied). This was carried out by CAAS Ltd with the support of Fehily and

Timoney and associates. The Wind Energy Strategy was supported by a SEA and Habitats Directive

Assessment (HDA) and the Environmental Report and Natura Impact Report (NIR) of both of these

assessments are set out in Volume 2, as Appendix 2 and 4. Therefore, for detailed analysis for the impact

of wind energy on the environment, reference should also be made to the Environmental Report prepared

for the SEA, and NIR prepared for the HDA as part of the Wind Energy Strategy.

1.2 The Tipperary Renewable Energy Strategy 2016

The vision for the Renewable Energy Strategy is set out in Section 1.2 of Volume 1 and the objective of the

Renewable Energy Strategy is as follows:

‘The Council will seek to support and facilitate the development of the renewable energy sector in

line with the strategic goals set out by the Department of Communications, Energy and Natural

Resources whilst balancing the need for new development with the protection of the environmental,

cultural and heritage assets of the county’.

The Renewable Energy Strategy is a planning framework to guide and facilitate the development of

renewable energy resources in Tipperary in order to comply with the objectives and targets of the

Governments National Renewable Energy Action Plan 2010. Guidance is given on the renewable energy

resources of the county, including solar, wind, biomass, geothermal and hydro and planning policy is set

out. It may be reviewed again as necessary after assessment of compliance with the national 2020 targets

and the contribution of Tipperary to these targets.


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1.3 Relationship with other plans or programmes

The Renewable Energy Strategy sits within a hierarchy of strategic plans and programmes that are set out

at an International, European, National, Regional and County level. This hierarchy is illustrated in detail in

Chapter 2 of Volume 2. The Renewable Energy Strategy follows the methodology of the SEAI regarding

the preparation of Local Authority Renewable Energy Strategies 2013.

2.0 SEA Methodology

Schedule 2A of the Planning and Development Regulations 2001, (as amended) sets out two main types of

criteria for determining whether a plan would be likely to have significant environmental effects:

(1) Characteristics of the plan

(2) Characteristics of the effects and of the area likely to be affected.

The Section 28 Guidelines for Regional Authorities and Planning Authorities, on the ‘Assessment of the

Effects of Certain Plans and Programmes on the Environment’ sets out a methodology for the preparation

of SEA having consideration to the requirement of the Directive. The SEA Guidelines set out a checklist of

information to be included in the environmental report, (see below). This checklist has been a useful tool in

the preparation of the environmental report. In addition, SEA and Habitats Directive Assessment (HDA)

have been carried out concurrently during the preparation of the Renewable Energy Strategy and Wind

Energy Strategy. Pre-Draft SEA Scoping was prepared and consultation was carried out with stakeholders

and the Environmental Authorities. The findings of the SEA and HDA are now for the comment of the

environmental authorities as part of variation no. 3 of the County Development Plan (as varied).

1) Outline of the contents and main objectives of the plan, and of its relationship with

other relevant plans and programmes

2) Description of relevant aspects of the current state of the environment and the

evolution of that environment without implementation of the plan

3) Description of the environmental characteristics of areas likely to be significantly

affected

4) Identification of any existing environmental problems which are relevant to the plan,

particularly those relating to European protected sites

5) List environmental protection objectives, established at international, EU or national

level, which are relevant to the plan and describe how those objectives and any

environmental considerations have been taken into account when preparing the plan

6) Describe the likely significant effects (1) on the environment (biodiversity, human

health, fauna, etc.)

7) Describe measures envisaged to prevent, reduce and as fully as possible offset any

significant adverse environmental effects of implementing the plan


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8) Give an outline of the reasons for selecting the alternatives considered, and a

description of how the assessment was undertaken (including any difficulties)

9) A description of proposed monitoring measures

10) SEA Statement


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3.0 Summary of the Baseline Environment

3.1 Introduction

This section sets out to:

Describe the relevant aspects of the current state of the environment and the evolution of that

environment without implementation of the plan

Describe of the environmental characteristics of areas likely to be significantly affected.

Identify any existing environmental problems which are relevant to the plan, particularly those

relating to European protected sites.

The following environmental aspects are identified in this section: Biodiversity, Flora and Fauna, Population

and Human Health, Soil, Water, Air and Climate, Material Assets, Cultural Heritage, Landscape and the

interrelationship between the above.

3.2 Likely evolution of the environment in the absence of a new Strategy

The Renewable Energy Strategy has been prepared to inform renewable energy policy of the County

Development Plan (as varied) and in particular updates existing policy on wind energy. In the absence of a

dedicated Renewable Energy Strategy, the existing policy for renewable energy would remain in force, as

set out in both County Development Plans., In this respect current planning policy and the provisions of

environmental relevant legislation would facilitate the management and protection of the environment.

However, the Renewable Energy Strategy provides additional provisions that will contribute towards the

management and protection of the environment on a consistent countywide basis, and will also support the

achievement of the binding renewable energy targets as set out. In the absence of the Renewable Energy

Strategy, such additional protection and management would not be provided and it is likely that energy

targets would not be achieved.

3.3 Biodiversity, Flora & Fauna

There is a variety of sensitive and designated areas in Tipperary on account of the species and habitats

which they contain. Such areas include the Silvermine Mountains (in the west of the County), the Galtee

Mountains (in the south), the Knockmealdown Mountains (in the south) and Slievenamon (in the south

west); Lough Derg (in the north east) and the County’s drainage network including the River Shannon and

River Suir which rises in the north of the County and exits at Carrick-on-Suir in the south west. Sensitive

habitats include peatlands, broad-leaved forests and rivers and streams while sensitive species include

fish, otters, birds and bats.


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Relevant ecological designations in Tipperary include:

Candidate Special Areas of Conservation (cSACs) and Special Protection Areas (SPAs);

Salmonid Waters;

Freshwater Pearl Mussel catchments9;

Natural Heritage Areas (NHAs) and proposed Natural Heritage Areas (pNHAs);

Article 10 of the Habitats Directive recognises the importance of ecological networks as corridors and

stepping stones for wildlife, including for migration, dispersal and genetic exchange of species of flora and

fauna. The Directive requires that ecological connectivity and areas of ecological value outside the Natura

2000 network of designated ecological sites are maintained.

3.3.1 Natura 2000 sites

The Habitats Directive seeks to establish Natura 2000, a network of protected areas throughout the EU. It

is the responsibility of each member state to designate SACs to protect habitats and species, which,

together with the SPAs designated under the 1979 Birds Directive, form Natura 2000.

SACs have been selected for protection under the European Council Directive on the conservation of

natural habitats and of wild fauna and flora (92/43/EEC) by the DECLG due to their conservation value for

habitats and species of importance in the European Union. Candidate sites are also protected because

they are currently under consideration by the Commission of the European Union.

SPAs have been selected for protection under the 1979 European Council Directive on the Conservation of

Wild Birds (79/409/EEC) - referred to as the Birds Directive – by the DECLG due to their conservation

value for birds of importance in the European Union.

Salmonid waters are designated and protected as under the European Communities (Quality of Salmonid

Waters) Regulations 1988 (SI No. 293 of 1988). Designated Salmonid Waters are capable of supporting

salmon (Salmo salar), trout (Salmo trutta), char (Salvelinus) and whitefish (Coregonus).

Freshwater pearl mussel is a globally threatened, longlived and extremely sensitive species that can be

impacted by many forms of pollution, particularly sediment and nutrient pollution and by hydrological and

morphological changes, which may arise from developments, activities or changes in any part of the

catchment.

The Renewable Energy Strategy is subject to HDA in accordance with the Habitats Directive to address the

protection of Natura 2000 sites. Natura 2000 sites are set out below.

3.3.2 Natural Heritage Areas

Natural Heritage Areas (NHAs) proposed NHAs and Margaritifera Sensitive Areas are illustrated on Figure

2.


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3.3.3 Landcover mapping

Figure 3 illustrates the 2012 CORINE classification of landcover under various headings. Land cover

categories in Tipperary which indicate lands that are likely to be most valuable to biodiversity include

broad-leaved forests, natural grassland, moors and heathlands, transitional woodland scrub, peat bogs,

stream courses and water bodies.

3.3.4 Existing Problems

Tipperary is a county with a wide range of land uses and significant urbanisation in a dispersed settlement

network and it is notable that use of land in the county is constantly in transition excepted in isolated upland

areas. Changes in land uses arising from human development can result in a loss of biodiversity and flora

and fauna, however, it is considered that there are not many significant existing problems in the county that

impact on biodiversity flora and fauna. The Department of Arts, Heritage and the Gaeltacht’s Article 17

report on the Status of EU Protected Habitats and Species in Ireland (2013) identifies many Irish habitats to

be of unfavourable status and many to be still declining, although it also identifies that a range of positive

actions are underway. The report identifies that the majority of EU protected species are, however, in

“Favourable” status in Ireland, and stable, although a small number are considered to be in “Bad” status

and continue to require concerted efforts to protect them.

It is noted in the Wind Energy Strategy review and the SEA prepared in respect to it that that there has

been significant wind energy development in parts of the county that is designated as an SPA1. This has

been examined in greater detail in the HDA for the Wind Energy Strategy (Appendix 4)

1 Slievephelims/Hollyford Hills


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Figure 2: Natura 2000 sites within 10Km of County Tipperary


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Figure 3: NHAs and other ecological Sites


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Figure 4: Corine Landcover mapping 2012


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3.4 Geology & Soils

3.4.1 Geology

There are three ages of rock formation represented widely in the region. Youngest of all are the

Carboniferous rocks (limestones) that are most widespread in Ireland, constituting most of the island’s low-

lying midlands. The limestones are in-turn stratified into Westphalian and Namurian (Upper Carboniferous -

the youngest rocks, underlying the Slieveardagh), and Dinantian (Lower Carboniferous - comprising the

remainder of the County’s plains and valleys). Beneath and occasionally protruding through the limestones

are the Old Red Sandstones of the Devonian Age. These mostly hard resistant quartzites, sandstones and

conglomerates. They now form the County’s uplands. At the crests of the Galtees, Slievenamon and the

Hollyford Hills, Silurian Age rocks, the oldest encountered in the County, have been exposed by erosion of

the Old Red Sandstones. These highly compacted slates, shales and greywackes formed between 400 and

435 million years ago. The major geological divisions within the County are those between the Lower

Carboniferous rocks and the Old Red Sandstones. The more substantial areas of Upper Carboniferous and

Silurian rocks have also been delineated.

3.4.2 Soils

The soils of Tipperary are a complex product of the bedrock geology and the various geomorphological

processes that have subsequently acted on the region, such as the spread and retreat of the ice sheet and

glaciers. This is reflected in the subsoil geology, which is dominated by limestone till (glacial deposits) on

the plains and shallow rock in the uplands. The principal soils of the uplands are Peaty Podzols, with low

nutrient status and peaty surface. Outcropping rock is common and the soils are poorly drained. These

characteristics limit the land capability to marginal grazing and forestry.

On the lower slopes of the uplands, Gleys are common. Being poorly drained, intermittently waterlogged,

sticky and hard to work, the land use capability here is similarly limited, although the material is deeper. In

the Slieveardagh hills and the western and eastern extents of the southern lowland plains (between the

major uplands) and in the areas north of Nenagh, there is widespread coverage of Acid Brown Earths.

These soils are similar in nature to the Brown and Grey Podzols that cover the northern and central plains.

They are deep, free draining and medium textured with a good moisture holding capacity, making the

majority of the county’s plains of wide land capability, suitable for high quality grassland and tillage. The

agricultural and equine resources of the county are to a large extend dependant on the quality of the soils

of the central plain.

To the north west of the Slieveardagh, there are extensive patches of Basin Peat, naturally very limited in

terms of land capability. Whilst this peatland is limited in its productive capacity, it is a unique lowland

resource in the county and offers a diverse peatland habitat that should be recognised. Peat and peaty

soils are most sensitive to wind energy development due to potential effects upon soil stability (and

consequent landslides or bogbursts) and ecology, refer to the SEA for the Wind Energy Strategy for more

detail on this.


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The major soils divisions within the County are therefore those between the high quality soils of the lowland

plains and the shallow, nutrient poor and poorly drained soils of the uplands and the peatland area in the

north east


In terms of baseline environment, the quality soils of the lowlands are highly productive and intensively

managed as an agricultural resource. The ability of this land to maintain it’s productively is vital to the

economy of the county. The soils of the uplands and the peat lands are less intensively managed and have

a lower economic productively, however, as a result of this have a greater diversity and this also enhances

the environmental and visual quality of the county.


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Figure 5: Soils of Tipperary


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3.5 Material Assets

Tipperary has a wealth of material assets including but not limited to private housing, transport and public

service infrastructure, commercial and industrial enterprises, the agricultural and equine industries, amenity

and recreational facilities, quarries and agricultural land (cultural assets dealt with below). The material

assets of the county that may be relevant for the production of renewable energy include natural resources

such as areas of uplands suitable for wind energy production, land banks suitable for the production of

crops and forests, water bodies etc, and man-made resources such as the county’s infrastructure including

road network, water supply network, wastewater network, electricity supply network, gas network etc. it will

be a function of the SEA to ensure that the sustainable development of renewable energy will not have a

detrimental impact on the important material assets of the county.


It was found that there has been no significant problems related to material assets related to renewable

energy development in the County.

3.6 Cultural Heritage

Tipperary has a wealth of architectural and cultural heritage and this is vital to the character of the county

and to its tourism industry. Protected structures are set out in the relevant Development Plans and are

given statutory protection in the Planning and Development Acts 2000, (as amended). Sites and

Monuments are protected by the National Monuments Act and identified in the relevant Development

Plans. There are 6 medieval walled towns in Tipperary, four of these are in the Irish Walled Towns

Network, and these are Cashel, Fethard, Clonmel and Carrick on Suir. The Heritage Plans prepared for

North and South Tipperary address cultural and natural heritage in general and sets out actions and

measures for its protection and maintenance.


There is often a perceived conflict between renewable energy developments and culture. Impact on cultural

heritage is often a concern of local communities who recognise the value of their local heritage and are

concerned with the potential for impact as a result of large industrial type developments. Impact on cultural

heritage as a result of wind energy development was raised as a concern at pre-draft consultation phase.

Impacts that could arise as a result on renewable energy development are related to the visual intrusion of

development i.e. wind turbines and solar panels on historic settings, and physical intrusion i.e. disturbance

of sub-surface remains as a result of excavations for geothermal heat, wind turbines, solar farms etc.

The preparation of the Renewable Energy Strategy has been carried out with careful consideration to the

cultural heritage of the county, including historic landscapes, protected structures, national and recorded

monuments and historic town centres. It has been found that there has been to date no significant conflicts

with legislative objectives governing archaeological and architectural heritage.


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Figure 6: Cultural Assets in the County.


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3.7 Population & Human Health

3.7.1 Population

Tipperary has a strong settlement structure based around its county town of Clonmel, its larger towns of

Nenagh and Thurles and its strong network of supporting towns and villages. There is also a well dispersed

rural population, and the county is populated over much of its area with the exception of the higher upland

areas and bogland areas to the extreme north of the county. The county traditionally has had a strong

agricultural and equine industry with population living on the land near their place of work.

3.7.2 Human Health

Tipperary is considered to be a quality place to live and its natural and cultural amenities and facilities

contribute to a high quality of life. It is envisaged that the reduction in the use of fossil fuels as proposed will

contribute to a higher quality of life through the lowering of the production of GHG emissions. However, it

will be a function of this SEA to ensure that the sustainable development of renewable energy will not have

a negative impact on human health.

Wind energy developments have resulted in concerns from members of the public in relation to potential

impact on human heath as a result of noise and shadow flicker in the vicinity of wind turbines. The

Department of Environment, Community and Local Government is currently carrying out a technical update

of the Wind Energy Development Guidelines 2006 with respect to noise (including separation distance) and

shadow flicker from wind energy developments. This update is intended to ensure that the Wind Energy

Guidelines are supported by a robust and up to date evidence base on these issues to support wind energy

development in a manner which safeguards residential amenity consistent with EU and National Policy.

Please refer to the SEA prepared for the Wind Energy Strategy for greater detail.

To date commercial scale renewable energy installation in Tipperary has been mostly for wind energy. It is

likely that over the lifetime of the Renewable Energy Strategy that there will be significant investment in

other resources such as energy from biomass, hydro and solar resources. Each of these have potential to

impact on humans in the absence of appropriate mitigation.


It is considered that there are no significant existing problems associated with the renewable energy

development and population and human health in the county.

3.8 Air/Climate Factors

A suite of new EU Directives setting out a completely new approach to the monitoring, assessment and

management of air quality has been adopted in recent years. The objectives include avoiding, preventing

and reducing the impact of harmful air emissions on human health and the environment. Ireland does not

have serious outdoor air quality problems. This is largely due to the eradication of the burning of coal in

many urban areas during the 1980s and the early 1990s. The biggest threat now facing our air quality is


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emissions from road traffic. Air pollution can affect the health and well-being of sensitive population groups

and eco-systems.

The Environmental Protection Agency (EPA) has overall responsibility for the co-ordination of ambient air

quality monitoring in Ireland in accordance with these EU Directives. The EPA and local authorities operate

monitoring stations. Tipperary is located within Air Quality Zone C and the current air quality in this zone is

of good status (taken from the monitoring point at the Limerick City Council laboratories on Park Road,

Reebogue, Limerick). It is likely that the implementation of the RES will have long-term benefits with

respect to air quality and climate change. However, any localised potential for adverse effects will be

managed through the appropriate procedures and controls such as EIA, IPC Licencing etc.

3.9 Landscape

The importance of landscape and visual amenity and the role of its protection are recognised in the

Planning and Development Act 2000 (as amended), which requires that Development Plans include

objectives for the preservation of the landscape, views and the amenities of places and features of natural

beauty. The importance of the landscape is also acknowledged by the Council and in view of this as part of

the Renewable Energy Strategy process, a review2 of the landscapes within County Tipperary was carried

out. The results of this landscape sensitivity analysis are shown on Figure 6. In addition, landscape

sensitivities in Tipperary and sensitivities in adjacent areas of the seven counties with which County

Tipperary shares its county boundary with (including those for counties Clare, Galway, Offaly, Laois,

Kilkenny, Waterford and Limerick) were considered during the preparation of the Renewable Energy

Strategy and the LCA.

In classifying the landscape of county Tipperary it was found that there are 4 landscape archetypes in the

County Illustrated on Figure 6:

A The Plains

B The Lakelands

C The Foothills

D The Uplands

These areas can then be subdivided and described in a set out 23 distinctive landscape character areas in

the county. Sensitive areas in the county include the uplands and foothills of the Silvermines Mountains,

Arra Mountains and the Devils Bit in the north of the County, the Slieveardagh Hills and Slievenamon in the

east and southeast of the County and the Galtee and Knockmealdown Mountains in the west and south of

the County. These areas are sensitive due to their elevation, slope, vegetation and soils. Other sensitive

areas include Lough Derg and those which contain peatlands and other semi-natural habitats in lowland

areas, including in the north and east of the county and urban and semi urban areas. Views listed and

2 Tipperary Landscape Character Assessment review 2016


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protected in Tipperary through the County Development Plans (as varied) include views of key heritage

sites and along scenic tourism routes. Such listed views will inform lower tier project assessments and

design.

The assessment of the landscape allows for guidance to be set out on the capacity of the landscape for

change having consideration to its sensitivity. Detailed guidance is set out in the Landscape Character

Assessment for Tipperary 2016; this has informed the Renewable Energy Strategy.

Figure 7: landscape Archetypes


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Figure 8: Range of Sensitivities including the dominant sensitivity in each LCA


Primary and subsequent ecological succession and new developments have resulted in changes to the

visual appearance of landscapes within County Tipperary overtime and it is considered that this is a natural

process of landscape change, however legislative objectives governing landscape and visual appearance

were not identified as being conflicted with. It is noted that adjoining counties sometimes take a different


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approach to designation of landscape sensitivity and capacity for change and this may result in conflicting

policy for development in the landscape i.e. wind energy designations. In view of this, the Wind Energy

Strategy and LCA were mindful of landscape designations in adjoining counties up to 5km from the county

boundary. This process ensures that there are no significant conflicts in planning policy for new

development across the county boundaries.

3.10 Water

3.10.1 Water Framework Directive

Since 2000, Water Management in the EU has been directed by the Water Framework Directive

2000/60/EC (WFD). The WFD requires that all Member States implement the necessary measures to

prevent deterioration of the status of all waters - surface, ground,estuarine and coastal - and protect,

enhance and restore all waters with the aim of achieving “good status”. All public bodies are required to

coordinate their policies and operations so as to maintain the good status of water bodies which are

currently unpolluted and improve polluted water bodies to good status.

Article 4 of the WFD sets out various exemptions for deterioration in status caused as a result of certain

physical modifications to water bodies. This is provided: all practicable mitigation measures are taken;

there are reasons of overriding public interest or the benefits to human health, safety or sustainable

development outweigh the benefits in achieving the WFD objective; there are no better alternatives; and

the reasons for the physical modification are explained in the relevant catchment management plan.

A new national river basin plan3 will be supported by sub plans at sub-regional scales. The country will be

divided into 46 catchment management units. The units are, in the main, based on the hydrometric areas

already in use, with the River Shannon being subdivided on the basis of the catchments of its major

tributaries. Within each of these catchments, assessments will be done at a sub-catchment scale to inform

and assist with targeting of actions to address the issues identified. The units relevant to Tipperary are:

15 Nore

16 Suir

25A Brosna

25B Lower Shannon

25C Lough Derg

25D Lower Shannon

WFD Monitoring Programmes are undertaken in Ireland by the EPA. Overviews of the status for monitored

waterbodies are published on an ongoing basis and are made available online. Up-to-date, detailed

3 Significant Water Management Issues in Ireland - Consultation Document (June 2015)


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information with respect to relevant water bodies will, as is normal practice, inform lower tier project

assessments and design.

3.10.2 Status of Surface Waters

For surface water, the WFD defines ‘status’ as the general expression of the status of a body of surface

water, determined by the poorer of its ecological status and its chemical status. Thus, to achieve ‘good

surface water status’ both the ecological status and the chemical status of a surface water body need to be

at least ‘good’.

Ecological status is an expression of the structure and functioning of aquatic ecosystems associated with

surface waters. Such waters are classified as of ‘good ecological status’ when they meet Directive

requirements.

Chemical Status is a pass/fail assignment with a failure defined by a face-value exceedance of an

Environmental Quality Standards (EQS) for one or more Priority Action Substances (PAS) listed in Annex X

of the Water Framework Directive (WFD). The EQS values for individual PAS substances are set at

European level. Good surface water chemical status means that concentrations of pollutants in the water

body do not exceed the environmental limit values specified in the Directive.

The most recent available information from the EPA (for the years 2010-2012) generally classifies surface

waters in County Tipperary as being of good or high status, however there are stretches of rivers and

streams which are classified as being of moderate and, to a lesser extent, poor status.

3.10.3 Status of Ground Waters

For groundwater bodies, the approach to classification is different from that for surface water. For each

body of groundwater, both the chemical status and the quantitative must be determined. Both have to be

classed as either good or poor. The WFD sets out a series of criteria that must be met for a body to be

classed as good chemical and quantitative status. The most recent available information from the EPA (for

the years 2007-2012) generally classifies ground waters in County Tipperary as being of good status.

3.10.4 Registers of Protected Areas

The WFD requires that Registers of Protected Areas (RPAs) are compiled for a number of water bodies or

part of water bodies which must have extra controls on their quality by virtue of how their waters are used

by people and by wildlife. The WFD requires that these RPAs contain: areas from which waters are taken

for public or private water supply schemes; designated shellfish production areas; bathing waters; areas

which are affected by high levels of substances most commonly found in fertilizers, animal and human

wastes - these areas are considered nutrient sensitive; areas designated for the protection of habitats or

species e.g. Salmonid areas; Special Areas of Conservation (SACs); and, Special Protection Areas

(SPAs).


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Entries to the RPAs in County Tipperary include:

The water bodies within and surrounding the County supporting Special Areas of Conservation

(SACs) and Special Protection Areas (SPAs);

Lough Derg, all of the groundwater underlying the County and stretches of certain stretches of

rivers, by virtue of the abstractions of drinking water taken from them;

Nutrient sensitive rivers (a stretch of the Nenagh River from Nenagh to Lough Derg, a stretch of the

River Suir downstream of Thurles and a stretch of the River Suir downstream of Clonmel);

Salmonid rivers, including stretches of the Rivers Aherlow and River Nore.

3.10.5 Flooding

It is a critical element of the SEA to consider the potential for flood risk as a result of development and to

ensure that the potential impact of flooding on new development is a careful consideration of the planning

process. It is also important to consider the impact of Climate Change on flood risk in the long-term.

Flooding is a multi-functional natural process which performs important ecological roles and which always

has and always will occur. In assessing planning applications, the Council has consideration to

classification of lands within Flood Zone A and Flood Zone B (as per JBA Flood Mapping for South

Tipperary purchased by the Council in 2010), the 1:100 and 1:1000 Year Preliminary Flood Risk Mapping

(PFRA) produced by the OPW in 2012 and draft flood risk maps produced by the OPW in 2015.

The OPW are currently preparing a South East Catchment Flood Risk Management Plan (CFRMP), A

Shannon Catchment Flood Risk Management Plan (SFRMP) and a River Suir CFRAM, these will identify

areas for flood management (generally based around urban areas) and will be important management tools

for flood risk areas in the future. Tipperary is primarily located in the Shannon and Suir River Catchments.

The OPW have identified Areas for Further Assessment (AFAs) and draft flood Maps were published in late

2015. Any new development proposed in the county will be required to demonstrate that it will not

contribute to flood risk in accordance with the Flood Risk Guidelines and having consideration to available

Flood Risk Mapping, including flood risk mapping from the OPW/RPS Suir CFRAMs and the relevant

CRFRAMs due to be published in 2016. Where appropriate the council will request the preparation of a

flood risk management plan to accompany planning applications.


It is noted that most of Tipperary’s surface waters and ground waters are classified as being of ‘good’

status, where waters are found to be less than ‘good’ in their status, the council in conjunction with the EPA

is seeking to improve these water bodies to at least ‘good’ status. It is noted that there is historic and

predictive evidence of flooding in various locations in County Tipperary.


26

4.0 SEA Objectives and Indicators

4.1 Strategic Environmental Objectives (SEOs)

The focus of the Renewable Energy Strategy is on the production and use of renewable energy in the

county as an alternative to the use of fossil fuels; therefore, it ultimately will assist in meeting environment

protection targets through the decrease in the use of fossil fuels and consequent reduced Green House

Gas (GHG) Emissions. However, notwithstanding this overall environmental benefit, SEA scoping was

carried out to determine the key environmental impact areas, and how these areas may be affected

(positive or negative) through the implementation of the Renewable Energy Strategy. The key Strategic

Environmental Objectives (SEOs) of the County Development Plan (as varied) are set out below:

TABLE 1: SEOS RELEVANT TO THE IMPLEMENTATION OF THE PLAN

Environmental

categories

SEOs

Biodiversity, Flora &

Fauna

1 Conserve the diversity of habitats and protected species

Water Quality and

Flooding

2

3

Promote sustainable water use based on long-term protection of available

water resources.

Protect and enhance the status of aquatic ecosystems and, with regard to

their water needs, terrestrial ecosystems and wetlands directly depending on

the aquatic ecosystems.

Landscape and

Visual Amenity

4 Conserve and enhance valued natural and historic landscapes and features

within them.

Air & Climatic Factors 5

6

7

8

Reduce all forms of air pollution.

Minimise emissions of greenhouse gases to contribute to a reduction and

avoidance of human-induced global climate change.

Reduce waste of energy, and maximise use of renewable energy resources.

Assess, plan and manage adaptation to climate change impacts.

Material Assets 9

10

Maximise the use of the existing built environment.

Avoid flood risk and / or coastal erosion in selecting sites for development.

Cultural Heritage 11 Promote the protection and conservation of the cultural, including

architectural and archaeological, heritage.

Population and

human health

12 Minimise noise, vibration and emissions from traffic, industrial processes and

extractive industry.

Soils & Geology 13

14

15

16

Maintain the quality of soils

Give preference to the use of brown field lands, rather than developing

greenfield lands.

Minimise the consumption of non-renewable sand, gravel and rock deposits.

Minimise the amount of waste to landfill.


27

4.2 Development Objectives

Chapter 4 of the Renewable Energy Strategy describes the energy resources and the likely forms of

installations that may occur in Tipperary. A distinction is made between small scale (Micro), auto-producers

and large scale/commercial development types. The infrastructure required for these developments are

already in place, however, it is likely that this will be supplemented as projects are developed. It is likely

that the implementation of the Renewable Energy Strategy may lead to and facilitate the following key

areas of development:

TABLE 2: ENVISAGED RENEWABLE ENERGY DEVELOPMENT

All forms of Auto production/Micro renewable energy installations – Wind turbines, solar panels, private

combined heat and power units, small scale anaerobic digestion etc.

Large scale/Commercial Renewable Energy Installations

Commercial Hydropower – Development of upland hydropower facilities to generate electricity from stored

water, development of lowland water resources through impoundment or diversion.

Commercial Bio-Energy – Anaerobic digestion (AD) fermentation facilities at the medium to large scale

(using biomass or bio-waste products), bio fuel production facilities, wood processing facilities etc

Commercial Wind Energy – Wind turbines on upland areas and individual turbines developed on sites to

provide for the energy needs of enterprise and industry.

Commercial Geothermal Units – Large scale geothermal collectors

Commercial Solar Units – large scale photovoltaic or solar collectors (roof or ground mounted)

Other technologies such as Combined Heat and Power (CHP) and District Heating (DH)

In the context of development that may arise as a result of the Renewable Energy Strategy there is

potential for interaction between the SEOs set out above and the development objectives. It is important to

note that many of the inter-relationships may be positive or neutral. There may also be potential for

negative interactions in the absence of appropriate mitigation measures and therefore it is important that all

interrelationships are properly considered through the SEA process.


28

4.3 Consultation with Statutory Environmental Authorities.

In April 2015, the Council submitted a detailed Renewable Energy Strategy Scoping Report to the statutory

Environmental Authorities in order to gain their input into the SEA Scoping Process for the RES. The

following were consulted:

1) Environmental Protection Agency

2) Department of the Environment, Community and Local Government

3) Department of Agriculture, Fisheries and Food

4) Department of Communications, Energy and Natural Resources

5) Department of Arts, Heritage and the Gaeltacht

6) Adjoining Planning Authorities

Responses are set out below:

Department of Arts, Heritage and the Gaeltacht, dated 28th

April 2015.

Wind energy developments have the potential to impact on SPAs, Planning for wind energy areas within

several lm of SPAs should be fully assessed for their potential to impact of such designated sites. (Habitats

Directive Scoping). Wind energy development also has the potential to impact on freshwater (candidate)

SACs, such as the River Mulkear and River Suir and their tributaries. It is recommended that any wind

energy development zones should be fully assessed with respect to their potential to impact on such

designated sites. Commercial Hydropower developments within or near SACs or NHAs also have the

potential to impact on such sites and careful consideration should be given to zoning within such sites.

Birdwatch Ireland has produced a Bird Sensitivity Map for Ireland and consideration should be given to this

as part of the RES. All commercial developments should also be considered in the context of any

powerlines or serviced that they require. The SEA should contain a detailed section on Cultural Heritage

that looks at all aspects of this resource, including both underwater archaeology and terrestrial heritage that

may be affected. The Sites and Monuments Record should be considered along with the Department’s

published policy in relation to the archaeological assessment of large-scale developments on sites where

there is no record of archaeological monuments. (Framework and Principles for the Protection of the

archaeological heritage) Duchas the Heritage Service. Archaeological Heritage Includes:


29

Department of Communications, Energy and Natural Resources, 2nd

June 2015

Geology should be assessed as part of the SEA for the RES as it is part of the Heritage and Environment

of the County. Geology should be considered under the heading – Soils and Geology. The SEA should

provide information on Soils and Geology. The Department also recommends that consideration be given

to Irish Geological and Geomorphological sites in the county as addressed by the IGH programmed of the

GSI, which identifies 16 categories of site. County Geological sites are identified under the national

heritage Plan and should be considered. Detailed data sources are referenced in the submission and

include references to: Land mapping, landslides and groundwater.

Department of Agriculture, Food and the Marine, 1st

May 2015

Reference is mainly made to potential impacts on a marine environment, this has no direct relevance to

Tipperary outside of limited estuarial waters at Carrick on Suir. Reference is also made to freshwater

aquaculture and freshwater quality, of relevance to the water environment of Tipperary. A detailed list of

references is set out.

EPA, 6th

May 2015

Specific comments on the RES are outlined under the following headings:

SEAI LARES Guidance

Water related considerations

Biodiversity

Landscape

Relationship with other plans and programmes

In combination - Cumulative effects

Cumulative sensitivity mapping

Consideration of alternatives

Phasing of RE developments

Regional authority Considerations

Consideration of adjacent Local Authorities


30

Services provisions

Overhead Powerlines

The RES should include a statement regarding what is the function of the RES and what it can and cannot

do. Where other plans and programme are responsible for implementing policies, objective and initiatives

these should be fully referenced. The submissions sets out the appropriate legislative framework and

matters to be considered in the preparation of the RES under the following headings:

Water

Slope stability and land susceptibility

Biodiversity

Air, noise and climatic considerations

Landscape Character Assessment

Geology

Infrastructure

Waste Management

Environmental Impact assessment

Strategic Environmental Assessment

EPA report - Irelands Environment 2012, main environmental challenges.

A schedule of environmental resources is set out with the submission.

Waterford County Council 11th

May 2015

Reference is made to a number of matters already addressed; the following additional measures are

outlined: The SEA should have required to the wind energy strategies and LCA of adjoining counties. A

regional perspective should also be considered in assessing cumulative impact of wind energy

development. SEA should have consideration to the Joint Waste Management Plan for the region.

Cultural assessment should also include demesne landscapes, historic gardens and industrial heritage.

Appropriate Information sources are outlined.

4.3.1 Conclusion

The submissions, comments and references to appropriate sources of data and baseline information as set

out in the submissions received will be very useful in the preparation of the Renewable Energy Strategy.

The SEA process will give due consideration to the submissions received.


31

5.0 Alternatives

The SEA Directive, requires that reasonable alternatives are considered, taking into account the overall

objectives of the strategy and the geographical study area. In producing the Renewable Energy Strategy

two alternatives based on growth scenarios for renewable energy where considered. In setting out

alternatives it is acknowledged that it is not possible to disregard growth scenarios for renewable energy

development without consideration to the legally binding 2020 targets as set out in the National Renewable

Energy Action plan (NREAP). Further detail related to this is set out in Chapter 3.0 of the Renewable

Energy Strategy.

In addition, it was decided that consideration of alternatives based on a focus on individual energy

resources i.e. wind, hydro, solar etc with limitations on others was not appropriate as such a limited

approach to energy would not meet 2020 targets and restrict innovation and most efficient use of

supporting infrastructure and opportunities. Furthermore, the lack of county targets for renewable energy

production resulted in difficulty in setting out specific alternatives based on energy production in Tipperary.

For the reasons set out above, it was decided to consider the two renewable energy alternative approaches

that could be taken by Tipperary County Council relating to energy policy.

Spatial alternatives in the form of zoning, have been considered for the Wind Energy Strategy. However,

given the range of renewable energy technologies and the county-wide renewable energy resource

potential available, it is considered reasonable to consider non-spatial alteratives for the overall Strategy,

with a focus on written policy, having consideration to the overiding need to support and facilitate

renewable energy development on a county-wide basis accross a wide range of technology potentials. The

alternatives below have been considered on the basis of a strategy for growth for renewable energy.

(a) BASELINE SCENARIO – ‘Business as usual’, where all policy measures currently legislated for up

to the end of 20144 are maintained. This could be a future in which no further policy actions or

measures are taken and where renewable energy strategies are not prepared. This would result in

a slow increase in the production of renewable energy however, would fail to meet national 2020

renewable energy targets and would not put in place the economic and societal frameworks

needed to continue renewable energy production to 2030 requirements. Failure to meet legally

binding targets would result in monetary fines and ultimately contribute to unsubstantial reductions

in GHG emissions and poor response to climate change mitigation measures.

(b) NREAP SCENARIO - This scenario is to occur in line with the implementation of the baseline

measures described above and in addition to these, the implementation of the NREAP and White

Paper for Energy 2015 targets and objectives. In addition, the implementation of the National

Energy Efficiency Action Plan 2022 (NEEAP) will achieve lower energy consumption overall due to

energy efficiency measures. This scenario sets out a vision for Tipperary to adopt a planning

4 Before publication of the White Paper for Energy 2015


32

framework for renewable energy that facilitates high levels investment across all the renewable

resources including wind, biomass, solar, hydro and geothermal where it can be demonstrated that

environmental impacts are not significant. This scenario is underpinned by Tipperary County

Councils commitment to renewable energy through its membership of the Covenant of Mayors.

5.1 Evaluation of Alternatives

This section set out a comparative evaluation of the environmental effects of implementing each alterative.

The alternatives are evaluations using compatibility critieria in order to determine how they would be likely

to affect the SEOs identified in Table 1.

Table 3: Criteria for appraising the effect of Alternatives on SEOs

Likely to

Improve

status of

SEOs to the

greatest

degree

Likely to

Improve

status of

SEOs to a

greater

degree

Likely to

Improve

status of

SEOs to a

lesser

degree

Least

Potential

Conflict with

status of

SEOs- likely

to be

mitigated

Most

Potential

Conflict with

status of

SEOs- likely

to be

mitigated

Probable

Conflict with

status of

SEOs-

unlikely to be

fully

mitigated

No

significant

interaction

with status of

SEOs

Table 4: Comparative Evaluation of Tier 1 Alternatives: Type of Strategy

Option

Likely to

Improve

status of

SEOs to the

greatest

degree

Likely to

Improve

status of

SEOs to a

greater

degree

Likely to

Improve

status of

SEOs to a

lesser

degree

Least

Potential

Conflict

with status

of SEOs-

likely to be

mitigated

Most

Potential

Conflict

with status

of SEOs-

likely to be

mitigated

Probable

Conflict

with status

of SEOs-

unlikely to

be fully

mitigated

No

significant

interaction

with status

of SEOs

BASELINE

SCENARIO

5, 6, 7, 8,

9, 16

1, 2, 3, 4, 10, 11, 12,

13, 14, 15,

NREAP

SCENARIO

5, 6, 7, 8,

9, 16,

1, 2, 3, 4,

10, 11, 12,

13, 14, 15,

5.2 Selected Alternative

The alternative selected for the development of the Strategy is Alternative B NREAP Scenario. This

alternative will have the following affects as a result of its implementation and will result in more

environmental benefits than the other alternative examined.


33

Will reduce all forms of air pollution.

Will minimise emissions of greenhouse gases to contribute to a reduction and avoidance of human-

induced global climate change.

Will reduce waste of energy, and maximise use of renewable energy resources.

Will assist in the planning and management of adaptation to climate change impacts.

Will maximise the use of the existing built environment, and,


At the same time, when compared with the other alternative this option will facilitate the protection and

management of the environment to a greater degree; and resulting in a reduced amount of potential

conflicts. By complying with appropriate mitigation measures - including those which have been integrated

into the Renewable Energy Strategy – potentially significant adverse environmental effects which could

arise as a result of implementing the Strategy would be likely to be avoided, reduced or offset.


34

6.0 Potential for Impact on the SEO’s

The Matrix below assesses the areas where the development likely to occur as a result of the Renewable

Energy Strategy may interact with the SEOs set out in this environmental report. Where it is identified that

there is potential for a significant adverse impact on an SEO, mitigation measures are proposed for

incorporation into the Renewable Energy Strategy.

Potential effects on SEOs are categorised as follows:

Significant beneficial impact

? Uncertain Impact

X Significant adverse impact

O No relationship, or insignificant impact.


33

TABLE 5: MATRIX OF INTERACTION OF EPO’S WITH DEVELOPMENT LIKELY TO OCCUR

Environmental

categories

EPOs Potential

Impact

(, ?, X, O)

Consideration of Development likely to occur in the context of the EPOs

Biodiversity,

Flora & Fauna

1. Conserve the

diversity of habitats and

protected species

? The development of renewable energy sources especially that element of the industry that relates to processing could

potentially have wide- ranging and localised adverse impacts on biodiversity through the construction and operation phases

of development.

The types of renewable energy development that could impact on Biodiversity, Flora and Fauna are generally the larger

scale or commercial systems such as biofuel/biomass processing, hydro-energy installations, large-scale wind energy

installations etc. More localised impacts could arise as a result of domestic scale installations such as small scale

hydropower installations, on-farm AD plants, wood chipping facilities etc. The greatest level of impacts could typically arise

at the construction phase particularly for wind energy and solar energy installations; however, for many of the

developments identified above the on-going operating of the facilities could result in environmental impacts. In addition the

decommissioning phase should be considered as part of any development. Appropriate planning policy for environmental

protection and mitigation measures should be incorporated into the Renewable Energy Strategy in support of the County

Development Plan Policy, to avoid conflict with the EPO for Biodiversity, Flora and Fauna. Where appropriate planning

conditions relating to decommissioning may be required for renewable energy installations to ensure site remediation at

end of life developments.

It has been established in the HDA prepared for this Renewable Energy Strategy, that there is potential an impact on SPAs

as result of wind energy development in the county, the cumulative impacts of high wind energy areas has also been

considered. This approach has resulted in a precautionary approach to wind energy areas zoning.

The demand for Biomass in Tipperary is likely to continue to increase as people move away from fossil fuels to more

sustainable and locally produced energy sources. The Renewable Energy Strategy has identified typical resources, and key

ones relate to agriculture and food by-products, energy crops, bio-waste and forestry. Forestry plantations and bio-energy


34

cropping do not normally require planning permission and therefore are not addressed in the planning framework of the

RES. Forestry in Ireland operates within a legal and regulatory framework. This is necessary in order to protect forests and

also to ensure that forestry operations and activities are carried out in compliance with the principles of sustainable forest

management. While most forestry operations are exempt from the requirement to obtain planning permission, some forestry

activities require, by law, a license or approval (consent) from the Department of Agriculture, Food and the Marine. It is a

condition of grant-aid, under the 2007-2013 Programme that development be compatible with the protection of the

environment. Environmental considerations at the time of application include water quality, designated habitats,

archaeology, landscape and size of area. Public agencies and the general public are consulted in relation to applications for

forestry grants in areas of special environmental sensitivity.

Water Quality

and Flooding

2. Promote sustainable

water use based on

long-term protection of

available water

resources.

3. Protect and enhance

the status of aquatic

ecosystems and, with

regard to their water

needs, terrestrial

ecosystems and

wetlands directly

depending on the

aquatic ecosystems.

? The protection of water quality in Tipperary is influenced by the extensive designation of water courses as Special Areas of

Conservation associated with the River Suir catchment and the requirements of the Water Framework Directive. The types

of renewable energy development that could impact on water quality (as a result of disturbance or abstraction/discharge)

are generally the larger scale or commercial systems such as biofuel/biomass processing, hydro-energy installations, bio-

energy/forestry cropping, large-scale wind energy installations etc. More localised impacts could arise as a result of

domestic scale installations such as small scale hydropower installations, on-farm AD plants, wood chipping facilities etc.

The greatest level of impacts could typically arise at the construction phase related to ground disturbance for installations

and associated infrastructure. However, for many of the developments identified above the on-going operating of the

facilities could result in environmental impacts. In addition the decommissioning phase should be considered as part of any

development.

Appropriate planning policy for environmental protection and mitigation measures should be incorporated into the

Renewable Energy Strategy in support of the County Development Plan (as varied) Policy, to avoid conflict with the EPO

for Water quality and flooding. The avoidance of flood risk or the exacerbation of existing flood risk should also be

considered in the county and consideration of flood risk areas and flood risk management plans (after publication of the

Shannon and South East CFRAMs) will be required as part of any planning proposal.


35

Landscape and

Visual Amenity

4. Conserve and

enhance valued natural

and historic landscapes

and features within

them.

? Certain aspects of the renewable energy sector can alter views and prospects, i.e. wind turbines, intensive forestry,

processing facilities, solar harvesting. There is also potential for localised visual impacts as a result of the development of

micro-renewables.

It is acknowledged that the greatest potential for impact on the character of the landscape (both urban and rural) will arise

as a result of solar and wind energy commercial scale installations. In addition, auto-producer and micro producers for solar

and wind have the potential to alter the character of the urban landscape.

In view of the potential for landscape change, an independent review of the current Tipperary Landscape Character

Assessments (LCA) was commissioned and this new review dated 2016 characterises the landscape, identifies sensitivity

areas and also set out guidelines on the capacity of the landscape of the county to accommodate change. Particular

consideration was given to land use types set out across the following categories: Agriculture and Forestry, Housing,

Urbanisation, Infrastructure, Extraction and energy. Consideration under the energy category was given to solar energy and

wind energy. The Renewable Energy Strategy acknowledges the role of Visual Impact Assessment as a tool to assist in the

assessment of visual impact on the urban and rural environment. Appropriate planning policy for protection and mitigation

measures should be incorporated into the Renewable Energy Strategy in support of the County Development Plan Policy,

to avoid conflict with the EPO for protection of natural and historic landscapes.

Air & Climatic

Factors

5. Reduce all forms of

air pollution.

6. Minimise emissions

of greenhouse gases to

contribute to a

reduction and

avoidance of human-

induced global climate

change.

It is envisaged that the increased focus on the production of energy from clean and renewable resources such as wind,

water and sunlight will over the long turn improve air quality and have a positive impact on climate change due to the

reduction in reliance on the burning of fossil fuels.

Adverse impact on air quality is likely to be most associated with biomass processing and burning. Domestic burning of

wood fuel is becoming more efficient and produces lower rates of emissions due to better quality stoves and technology.

Emissions may occur at the large scale in the event of the location of a large scale bio fuel processing facility in the county

i.e. wood pellet manufacturing or bio-fuel processing.

The greatest level of impacts could typically arise at the construction phase; however, for many of the developments

identified above the on-going operating of the facilities could result in environmental impacts. In addition the


36

7. Reduce waste of

energy, and maximise

use of renewable

energy resources.

8. Assess, plan and

manage adaptation to

climate change

impacts.

decommissioning phase should be considered as part of any development. Appropriate planning policy for environmental

protection and mitigation measures should be incorporated into the RES in support of the County Development Plan Policy,

to avoid conflict with the EPO for Air Quality and Climate Change.

Material Assets 9. Maximise the use of

the existing built

environment.

10. Avoid flood risk and

/ or coastal erosion in

selecting sites for

development.

?, It is acknowledged in the Renewable Energy Strategy that sustainable use must be made of material assets in place in

Tipperary that facilitate the renewable energy sector. Such assets include: the national road and rail network, the national

grid, the gas network etc. Eirgrid and ESB Networks and Bord Gáis Ireland manage and operate the national energy

networks and connection to these networks is controlled by a grid connection application process. In assessing proposals

for renewable energy developments, particular consideration will be given to the impact on the county road network. This is

particularly relevant in the case of bioenergy developments where the raw material along with the by-product may require

transportation to and from the processing site.

The potential for impacts on certain material assets could arise as a result of significant changes in agricultural practices i.e.

through bio-energy cropping and the erection of on-site AD plants. However, it is considered appropriate that on-farm AD

process should be become part of normal farming practices and will not result in any change to material assets subject to

normal planning controls.

It is accepted that innovation will be required with respect to renewable energy and it can be expected that new

technologies, designs and materials and finishes to the built environment will be proposed in the county over the lifetime of

the Renewable Energy Strategy. Therefore, flexibility will be required to accommodate these necessary innovations. The

Renewable Energy Strategy and the County Development Plan (as varied) is clear on what aspect of material assets are of

value and should not be subject to material; change and the implementation of normal planning criteria will ensure this.


37

The use of CHP technologies will result in a positive impact on material assets through the recovery and use of waste heat.

Localised impacts on the assets of the county in general i.e. infrastructure, could arise as a result of individual proposals for

development, however, the application of normal development management standards will ensure that impacts are

mitigated.

Cultural

Heritage

11. Promote the

protection and

conservation of the

cultural, including

architectural and

archaeological,

heritage.

O In general, there is no direct conflict between cultural heritage and renewable energy where appropriate mitigation

measures considered and applied. Potential for impacts may arsier as a result if solar energy and in energy installations

sited and designated in an appropriate manner in sensitive urban locations, however, normal planning controls will avoid

this conflict. There is also potential for disturbance of sub-surface remains as a result of certain installations where

significant ground clearance is required, particularly at construction phase in geothermal, solar and wind energy

developments. Planning controls such as archaeological monitoring will be required in such instances.

It is accepted that innovation will be required with respect to renewable energy and it can be expected that new

technologies, designs and materials and finishes to the built and man-made environment will be proposed in the county

over the lifetime of the Renewable Energy Strategy, for example, typical house designs may change to accommodate solar

and geothermal technologies. Therefore, flexibility will be required to accommodate these necessary design innovations.

The Renewable Energy Strategy and the County Development Plan (as varied) is clear on what aspect of material assets

and natural and cultural assets are of value and should not be subject to material; change and the implementation of

normal planning criteria will ensure this.

It is considered that the implementation of the Renewable Energy Strategy will not have significant negative impacts on the

cultural heritage of the plan area. Local impacts that may arise may be mitigated through the normal planning process.

Population and

human health

12. Minimise noise,

vibration and emissions

from traffic, industrial

processes and


O It is considered that the implementation of the Renewable Energy Strategy will not have significant negative impacts on the

human health of the population of the plan area. Local impacts that may arise may be mitigated through the planning

process.

Soils & Geology 13. Maintain the quality O, It is considered that the implementation of the Renewable Energy Strategy will not have significant negative impacts on the


38

of soils

14. Give preference to

the use of brown field

lands, rather than

developing Greenfield

lands.

15. Minimise the

consumption of non-

renewable sand, gravel

and rock deposits.

16. Minimise the

amount of waste to

landfill.

soils and geology of the plan area. Impacts are generally localised and associated with ground disturbance as result of

development in upland or peatland areas, these include landslides or bog bursts, such impacts may be mitigated through

the planning process.

The Renewable Energy Strategy acknowledges the potential for municipal waste to contrite to renewable energy production

and specially sees a role for Biowaste in the biomass industry as a feedstock along with agricultural waste. This alternative

waste disposal method will support the SEO relating to minimising the amount of waste to landfill.


39

7.0 Incorporation of mitigation measures

This SEA process is concerned with ensuring that the implementation of the Strategy will have the

minimum impact on the environment having consideration to alternatives. It has been determined that the

implementation of the Renewable Energy Strategy will have in certain cases an impact on the environment

(SEOs), therefore, it is necessary to ensure that the Renewable Energy Strategy incorporates measures to

mitigate and minimise any adverse impact on the environment. The recommended mitigation measures

are addressed below:


40

TABLE 6: MITIGATION MEASURES

Environmental

categories

Environmental

Protection Objectives

(EPOs)

Mitigation measure proposed


Fauna

1. Conserve the

diversity of habitats and

protected species

All renewable energy projects proposed will individually be assessed against the requirements of the Environmental Impact

Assessment (EIA) Guidelines and Habitats Directive and through the EIA and Appropriate Assessment process will be

required to demonstrate that they will not have an adverse impact on any Natura 2000 sites or site otherwise designated

before they will be permitted to proceed. In this respect all new development in the County must comply with the provisions

of the County Development Plan (as varied) as they relate to Biodiversity, Flora & Fauna . This provision is explicitly

supported by policy RE 1: Protection of the Environment.

In view of the potential for conflict between wind energy development and Natura 2000 sites a detailed SEA and HDA

process has been carried out for the Wind Energy Strategy review. As a precautionary approach and result mitigation

measures are incorporated in the Wind Energy Policy set out in this Renewable Energy Strategy.

Water Quality and

Flooding


water use based on

long-term protection of

available water

resources.

3. Protect and enhance

the status of aquatic



needs, terrestrial

ecosystems and

wetlands directly

depending on the

Large scale proposals for processing and energy infrastructure will be subject to the planning process. Key to this process

will be an assessment of the environmental suitably of any site for the development proposed. The Planning Authority will

consult with the EPA and the Department of the Environment, Community and Local Government along with the other

statutory bodies to ascertain whether a development would have an acceptable impact on the environment.

This Environmental Report has examined the full range of environmental parameters applicable to the development of

renewables and in Section 6.0 of the Renewable Energy Strategy sets out the policy of the Council with respect the

development of renewable energy projects, this policy will guide and inform the general public and developers alike with

respect the suitability of any site for renewable energy development in Tipperary.

In this respect all new development in the County must comply with the provisions of the County Development Plan (as

varied) as they relate to water quality and flooding. This provision is explicitly supported by Policy RE 1: Protection of the

Environment.


41

aquatic ecosystems.

Landscape and

Visual Amenity

4. Conserve and

enhance valued natural

and historic landscapes

and features within

them.

In view of the potential for landscape change, an independent review of the current Tipperary Landscape Character

Assessments (LCA) was commissioned and this new review dated 2016 characterises the landscape, identifies sensitivity

areas and also set out guidelines on the capacity of the landscape of the county to accommodate change. Particular

consideration was given to land use types set out across the following categories: Agriculture and Forestry, Housing,

Urbanisation, Infrastructure, Extraction and energy. Consideration under the energy category was given to solar energy and

wind energy. The RES acknowledges the role of Visual Impact Assessment as a tool to assist in the assessment of visual

impact on the urban and rural environment. Appropriate planning policy for protection and mitigation measures are

incorporated into the RES in support of the County Development Plan Policy, to avoid conflict with the EPO for protection of

natural and historic landscapes. This is set out in Policy RE2: Landscape Capacity and Renewable Energy Development.

In applying the Wind Energy policy of the County Development Plan, the Council will actively encourage developers and

investors to engage with local communities to ascertain their concerns with respect new development, to undertake to

address these concerns where feasible and to consider the setting up of appropriate community investment funds or

schemes that will help to confer a gain to the local community in areas where it is proposed to install large-scale renewable

energy developments. In this respect, reference should be made to policy RE3: Community Investment in Local Renewable

Energy

In applying the Wind Energy policy of the County Development Plan, the Council will actively encourage developers and

investors to consider the cumulative impact of wind energy development in areas where wind developments have already

been permitted. Reference in this respect may be made to the Wind Energy Guidelines 2006 and to the Scottish Natural

Heritage Guidelines - Assessing the Cumulative Impact of on-Shore Wind Energy Developments 2012.

Air & Climatic

Factors

5. Reduce all forms of

air pollution.

6. Minimise emissions of

greenhouse gases to

contribute to a reduction

All renewable energy projects proposed will be individually assessed against the requirements of the Environmental Impact

Assessment (EIA) Guidelines and the Birds and Habitats Directive and through the EIA and Appropriate Assessment

process will be required to demonstrate that they will not have an adverse impact on air and climate before they will be

permitted to proceed.

In this respect all new development in the County must comply with the provisions of the County Development Plan (as


42

and avoidance of

human-induced global

climate change.

7. Reduce waste of

energy, and maximise

use of renewable

energy resources.

8. Assess, plan and


climate change impacts.

varied) as they relate to Air and Climatic factors. This provision is explicitly supported by Policy RE 1: Protection of the

Environment.

The Renewable Energy Strategy is in itself instrumental as part of the process of climate change adaption as it will facilitate

a move away from fossil fuel use with resultant GHG emissions. This is dealt with in detail in section 1.3 of the Renewable

Energy Strategy.

The Renewable Energy Strategy acknowledges the potential for municipal waste to contribute to renewable energy

production and specially sees a role for Biowaste in the biomass industry as a feedstock along with agricultural waste. This

alternative waste disposal method will support the SEO relating to minimising the amount of waste to landfill. In this respect,

reference should be made to Policy RE8: Waste to Energy.

Material Assets 9. Maximise the use of

the existing built

environment.

10. Avoid flood risk and

/ or coastal erosion in

selecting sites for

development.

It is recognised that renewable energy infrastructure cannot always be located on lands that is zoned for industry and

employment and in certain cases i.e. in the case of the development of farm based anaerobic digestion facilities will be

appropriately located on farms and the development of wood chipping facilities will required to be located close to both

wood supplies and to the end-users. This is recognised. However, for very large scale processing facilities the council will

give careful consideration to the ability of the site to accommodate new development, important considerations will be

impact on infrastructure, water quality, human health etc. Traffic Impact Assessment may be required as appropriate. In

addition to this, the council will also give consideration to the use of waste heat from energy processes through the use of

CHP technologies and District Heating. In this respect, the location of energy facilities in urban areas where waste heat can

be used in heating systems will be encouraged. Reference should be made to Section 6.6.1 Bioenergy Development in

Tipperary.

The minimisation of flood risk continues to be an important consideration of the Council and in assessing any planning

application the planning authority will have consideration to flood risk potential. Flood risk mapping as currently available

and that will be available through the OPW CFRMPS will be applied. Flood Risk Assessment may be required where

appropriate

Cultural Heritage 11. Promote the In respect to this SEO all new development in the County must comply with the provisions of the County Development Plan


43

protection and

conservation of cultural

assets, including

architectural,

archaeological and

heritage.

(as varied) as they relate to Cultural Heritage. New development proposals will be assessed for compliance with the polices

and objectives of the County Development Plan as set out in Chapter 7. Particular reference should be made to the

following policies:

Policy LH13: Protected Structures

Policy LH14: Architectural Conservation Areas

Policy LH15: Architectural Heritage of Local Interest

Policy6 LH16: Archaeology and Cultural Heritage

Population and

Human Health

12. Minimise noise,



processes and


In respect to this SEO, all new development in the County must comply with the provisions of the County Development Plan

(as varied) as they relate to Development Management Standards for new development. New development proposals will

be assessed for compliance with the policies and objectives of the County Development Plan as set out in Chapter 10. In

addition, the appropriate government guidance will be applied to all new development.

Soils and Geology 13. Maintain the quality

of soils

14. Give preference to

the use of brown field

lands, rather than

developing Greenfield

lands.

15. Minimise the

consumption of non-


and rock deposits.

16. Minimise the amount

of waste to landfill.

In respect to this SEO, all new development in the County must comply with the provisions of the County Development Plan

(as varied) as they relate to Development Management Standards for new development. New development proposals will

be assessed for compliance with the policies and objectives of the County Development Plan as set out in Chapter 10. In

addition, the appropriate government guidance will be applied to all new development.

In addition, this Strategy notes the potential for waste material such as organic waste to contribute as a feed stock to

energy recovery process such as anaerobic digestion. Reference should be made to Policy RE8: Waste to Energy.


44

8.0 Monitoring Proposals

8.1 Introduction

The SEA Directive requires that the significant environmental effects of the implementation of plans and

programmes are monitored. This section details the measures which will be used in order to monitor the

likely significant effects of implementing the Renewable Energy Strategy. Monitoring can enable, at an

early stage, the identification of unforeseen adverse effects and the undertaking of appropriate remedial

action.

Monitoring is based around indicators which allow quantitative measures of trends and progress over time

relating to the SEOs used in the evaluation. Each indicator to be monitored is accompanied by the target(s)

which were identified with regard to the relevant strategic actions. The table overleaf shows the indicators

and targets which have been selected for monitoring the likely significant environmental effects of

implementing the Renewable Energy Strategy, if unmitigated.

The Monitoring Programme may be updated to deal with specific environmental issues - including

unforeseen effects - as they arise. Such issues may be identified by the Council or identified to the Council

by other agencies.

The Council has set out a consolidated environmental monitoring programme for each of its existing

Development Plans. Monitoring is already carried out in accordance with the SEA directive for the following

Environmental Categories:

1. Flora and Fauna/Biodiversity/Protected Species

2. Population/Human Health/Quality of Life

3. Soil

4. Water quality and flooding

5. Climate Change

6. Material Assets

7. Cultural Heritage

8. Landscape views and Visual Amenity

The monitoring carried out for this Strategy will supplement the existing monitoring programme in place.

8.2 Monitoring for the Renewable Energy Strategy

In view of the specific effects associated with renewable energy development likely to occur it is proposed

that in addition to the existing monitoring targets of the County Development Plan (as varied), that

additional monitoring objectives that relate to the development of the renewable energy industry should be

incorporated into the County Development Plan monitoring programme. The monitoring programme as set


45

out in the Wind Energy Strategy5 will be carried out concurrently with the Renewable Energy Strategy

monitoring programme set out below.

Article 10 of the SEA Directive requires Member States to monitor the significant environmental effects of

the implementation of plans “in order, inter alia, to identify at an early stage unforeseen adverse effects and

to be able to undertake appropriate remedial action.” Existing monitoring arrangements may be used if

appropriate, to avoid duplication of monitoring [Source: Chapter 7 Implementation of SEA Directive

(2001/42/EC): Assessment of the Effects of Certain Plans and Programmes on the Environment Guidelines

for Regional Authorities and Planning Authorities. DoEHLG 2004].

A stand-alone Monitoring Report on the significant environmental effects of implementing the County

Development Plan (including the Renewable Energy Strategy) will be prepared in advance of the review of

the County Development Plan.

The monitoring programme for the Renewable Energy Strategy is set out below in Table 7.

5 Refer to Section 10 of Environmental report prepared for the Wind Energy Strategy for details of the monitoring programme for wind

energy development


46

TABLE 7: ENVIRONMENTAL MONITORING SPECIFIC TO RENEWABLE ENERGY DEVELOPMENT

Environmental

Component

Strategic Environmental

Objective

Selected Indicator(s) Selected Target(s) Data Source

Biodiversity,

Flora and

Fauna

1. Conserve the diversity of

habitats and protected

species

Conservation status of habitats

and species under Arcticle 17 of

the Habitats Direcitve,.

Maintenance of favourable

conservation status for all

habitats and species protected

under National and

International legislation to be

unaffected by implementation

of the Strategy.

Internal monitoring of likely significant

environmental effects of grants of permission

(grant by grant).

Department of Arts, Heritage and the Gaeltacht

report of the implementation of the measures

contained in the Habitats Directive - as required by

Article 17 of the Directive

Department of Arts, Heritage and the Gaeltacht:

National Monitoring Report for the Birds Directive

under Article12. Consultations with the NPWS.

Percentage loss of function

connectivity without remediation

reseutling from the development

provided by the Strategy

No signficant ecological network

or parts thereof with provide

functional connectivesly to be lose

without remedicastion resulting

from the development provided in

the Strategy.

Number of significant impacts on

relevant habitats, species,

environmental features or other

sustaining resources in

designated sites including

Wildlife Sites resulting from

development provided for by the

Strategy

Avoid significant impacts on

relevant habitats, species,

environmental features or other

sustaining resources in

designated sites including Wildlife

Sites resulting from development

provided for by the Strategy


47

Number of significant impacts on

the protection of listed species

No significant impacts on the

protection of listed species

Water Quality

and Flooding


water use based on long-

term protection of available

water resources.

3. Protect and enhance the

status of aquatic



needs, terrestrial

ecosystems and wetlands

directly depending on the

aquatic ecosystems.

Classification of Overall Status

(comprised of ecological and

chemical status) under the

European Communities

Environmental Objectives

(Surface Waters) Regulations

2009 (SI No. 272 of 2009)

Not to cause deterioration in the

status of any surface water or

affect the ability of any surface

water to achieve ‘good status’6

Department of Arts, Heritage and the Gaeltacht

report of the implementation of the measures

contained in the Habitats Directive - as required by

Article 17 of the Directive.

Department of Arts, Heritage and the Gaeltacht’s

National Monitoring Report for the Birds Directive

under Article12. Consultations with the NPWS. Groundwater Quality Standards

and Threshold Values under

Directive 2006/118/EC

Not to affect the ability of

groundwaters to comply with

Groundwater Quality Standards

and Threshold Values under

Directive 2006/118/EC

Number of incompatible

developments granted

permission on lands which pose

- or are likely to pose in the

future - a significant flood risk

Minimise developments granted

permission on lands which pose -

or are likely to pose in the future -

a significant flood risk in

compliance with The Planning

System and Flood Risk

Management Guidelines for

Planning Authorities

6 Good status as defined by the WFD equates to approximately the following in the current national schemes of classification as set out by the EPA:

Q4 in the biological classification of rivers; and Unpolluted status in the Assessment of Trophic Status of Estuaries and Bays in Ireland (ATSEBI).


48

Landscape

and Visual

Amenity

4. Conserve and enhance

valued natural and historic

landscapes and features

within them.

Number of complaints received

from statutory consultees

regarding avoidable adverse

visual impacts on the landscape

resulting from development

which is granted permission

under the Strategy

No developments permitted which

result in avoidable adverse visual

impacts on the landscape

resulting from development which

is granted permission under the

Strategy



(grant by grant).

Air and

Climatic

factors

5. Reduce all forms of air

pollution.


greenhouse gases to

contribute to a reduction

and avoidance of human-


change.

7. Reduce waste of energy,

and maximise use of

renewable energy

resources.

8. Assess, plan and


climate change impacts.

Percentage electricity

consumption from renewable

heat.

Percentage Heat Consumption

from renewable energy.

Contribute towards an increase in

electricity consumption from

renewable energy



renewable energy.

SEAI and TEA

Percentage Transport Energy

from renewable energy.



renewable energy.

Number of CHP facilities

permitted in Tipperary.

Increased investment in CHP

technologies in installations that

produce waste heat.

The contribution of Tipperary

towards 2020 renewable energy

targets.

Reduction in use of fossil fuels.


49

Material

Assets

9. Maximise the use of the

existing built environment.

10. Avoid flood risk and / or

coastal erosion in selecting

sites for development.

Proportion of new renewable

energy developments located in

areas which already

accommodate sub-stations and

power lines.

Proportion of new biomass

facilities located in close

proximity to the source of

feedstock and final markets in

order to avoid excessive

transportation of feedstock and

products.

No commercial renewable

energy development to be

located in a flood plain.

New energy developments to be

located in areas that already

accommodate substations and

power lines until these areas

reach capacity.

New biomass processing facilities

to be located close to source of

feedstock and final markets for

heat, biomass ort soil

conditioner/fertiliser whichever is

relevant.

New developments to be

assessed in accordance with the

Flood Risk Guidelines 2009.


environmental effects of grants of permission.

Cultural

Heritage

11. Promote the protection

and conservation of

cultural assets, including

architectural,

archaeological and

heritage.

Percentage of entries to the

Record of Monuments and

Places - including Zones of

Archaeological Potential (and

the context of the above within

the surrounding landscape

where relevant) - protected from

significant adverse effects

arising from new development

granted permission under the

Strategy

Protect entries to the Record of

Monuments and Places - including

Zones of Archaeological Potential

(and their context of the above

within the surrounding landscape

where relevant) from significant

adverse effects arising from new

development granted permission

under the Strategy



(grant by grant).

Consultation with Department of Arts, Heritage

and the Gaeltacht


50

Percentage of entries to the

Record of Protected Structures

and Architectural Conservation

Areas and their context

protected from significant



under the Strategy

Protect entries to the Record of

Protected Structures and

Architectural Conservation Areas

and their context from significant



under the Strategy

Population and

Human Health

12. Minimise noise,



processes and extractive

industry.

Occurrence (any) of a

spatially concentrated

deterioration in human health

arising from environmental

factors resulting from renewable

energy development, as

identified by the Health Service

Executive and Environmental

Protection Agency

No spatial concentrations of

health problems arising from

environmental factors as a result

of implementing the Renewable

Energy Strategy



Reports on environmental complaints received by

the Council.

Consultations with EPA and Health Service

Executive.

Soils and

Geology

13. Maintain the quality of

soils

14. Give preference to the

use of brown field lands,

rather than developing

Greenfield lands.

15. Minimise the

Where soil is disturbed or where

groundwork’s occur as a result

of new development, ensure that

appropriate remediation and

management measures are

applied.

Consider susceptibility of

All renewable energy

developments, particularly, wind

and solar, shall be assessed to

ensure that they set out

appropriate methodologies and

will be subject to conditions

requiring site management and

maintenance of soil during

construction and after installation




51

consumption of non-


and rock deposits.

16. Minimise the amount of

waste to landfill.

landslide/bogbursts as part of

the development management

process.

of infrastructure.

For all grants of planning

permission consider the findings

of landside/bogbursts

susceptibility assessments.

No landslides or bogbursts

occurring as a result of new wind

energy or associated development


51

Appendix 1: Non-Technical Summary

Section 1 Introduction and Terms of Reference

Introduction and Plan area

This is the Non-Technical Summary of the Environmental Report of the Draft Tipperary Renewable Energy

Strategy 2016 - Strategic Environmental Assessment (SEA). The purpose of the report is to provide a clear

understanding of the likely environmental consequences of the implementation of the policy and objectives

of the Tipperary Renewable Energy Strategy as part of the overall planning framework of the County

Development Plan (as varied).

The Draft Renewable Energy Strategy for Tipperary has been prepared to provide a county-wide planning

framework for Renewable Energy Development in County Tipperary. The Renewable Energy Strategy will

be incorporated by way of Variation No. 3 of the North Tipperary County Development Plan 2010 (as

varied) and Variation No. 3 of the South Tipperary County Development Plan 2009 (as varied).

Development Plan Areas

The County Development Plan areas are illustrated below. This Environmental Report and SEA has been

prepared in respect of Variation no. 3 in compliance with the requirements set out under the Act. In this


52

regard, it should be noted, that given the county-wide scope and nature of the Renewable Energy Strategy,

the Council has considered collectively and individually (as appropriate) the impacts of the proposed

Variations to both Development Plans. Therefore, this SEA will provide a consistent assessment across the

existing Development Plan areas. For clarity, all maps and illustrations contained in the report, defines both

Development Plan areas.

What is an SEA?

SEA is a systematic process of predicting and evaluating the likely environmental effects of implementing a

proposed plan, or other strategic action, in order to ensure that these effects are appropriately addressed at

the earliest appropriate stage of decision-making on a par with economic and social considerations. The

SEA is being carried out in order to comply with the provisions of the SEA Regulations and in respect to the

implementation of the Renewable Energy Strategy.

How does it work?

The main environmental issues of county Tipperary are assembled and presented to the team who are

preparing the new Plan. This helps them to devise a plan that protects whatever is sensitive in the

environment. It also helps to identify wherever there are environmental problems in the area - so that these

won’t get any worse - and ideally the plan tries to improve these. To decide how best to make a plan that

protects the environment as much as possible the planners examine alternative versions of the plan. This

helps to highlight the type of plans that are least likely to harm the environment.

Section 2: The Tipperary Renewable Energy Strategy

Why prepare Renewable Energy Strategy?

Ireland currently imports approximately 85% of the energy it consumes every year in the form of fossil

fuels, this comes at a high economic price (almost 6 billion a year) and has long-term consequences for the

environment as a result of the greenhouse gas emissions that result from the burning of fossil fuels.

Tipperary has committed to the reduction in the use of fossil fuels and wishes to continue to be a leader in

investment in sustainable renewable energy. In order to facilitate this vision, it has prepared a draft

Renewable Energy Strategy to put in place a county wide planning policy framework to give clarity to

investors and communities alike.

Spatial and written planning framework for Wind Energy

The Renewable Energy Strategy is set out over seven chapters and is supported by a Wind Energy

Strategy set out in Appendix 1. The Strategy was also informed by the preparation of a Landscape

Character Assessment for the county. The Strategy sets out planning policies and objectives for the

sustainable development of renewable energy in the county across the energy resources of wind, biomass,

solar, hydro, geothermal etc and provides clarity for communities and investors.


53

Section 3: Environment of Tipperary

Chapter 3 of the SEA examines in the detail the baseline status of the environment of Tipperary. The

environment is assessed under the following headings:

Biodiversity and Flora and Fauna

Geology and Soils

Materials Assets

Cultural Heritage

Population Human Health

Air/Climate

Landscape

Water

It was found that the environment of Tipperary is complied of a wide variety of elements and is influenced

by the landscape, geology and water environment of the county. In addition, the overall environmental

character is influenced significantly by mans own activities and by the dispersed form of settlement in

evidence in the county. Further detail on landscape Character can be found in the Landscape Character

Assessment for Tipperary 2016. It was found that there are no significant environmental problems in

evidence in Tipperary.

Section 4: Alternative Plan Scenarios

It is envisaged that the implementation of the Strategy will result in the forms of development set out below:

Table 2: Envisaged Renewable Energy Development

All forms of Auto production/Micro renewable energy installations – Wind turbines, solar panels, private

combined heat and power units, small scale anaerobic digestion etc.

Large scale/Commercial Renewable Energy Installations

Commercial Hydropower – Development of upland hydropower facilities to generate electricity from stored

water, development of lowland water resources through impoundment or diversion.

Commercial Bio-Energy – Anaerobic digestion (AD) fermentation facilities at the medium to large scale

(using biomass or bio-waste products), bio fuel production facilities, wood processing facilities etc

Commercial Wind Energy – Wind turbines on upland areas and individual turbines developed on sites to

provide for the energy needs of enterprise and industry.

Commercial Geothermal Units – Large scale geothermal collectors

Commercial Solar Units – large scale photovoltaic or solar collectors (roof or ground mounted)

Other technologies such as Combined Heat and Power (CHP) and District Heating (DH)


54

In order to determine the impact of these forms of development on the baseline environment, strategic

environmental protection objectives (SEOs) were prepared based on the evaluation of the baseline

environment. In total 16 SEOs were identified and are set out below.

SEOs relevant to the implementation of the Plan

Environmental

categories

SEOs


Fauna

1 Conserve the diversity of habitats and protected species

Water Quality and

Flooding

2

3

Promote sustainable water use based on long-term protection of available

water resources.

Protect and enhance the status of aquatic ecosystems and, with regard to

their water needs, terrestrial ecosystems and wetlands directly depending on

the aquatic ecosystems.

Landscape and

Visual Amenity

4 Conserve and enhance valued natural and historic landscapes and features

within them.

Air & Climatic Factors 5

6

7

8

Reduce all forms of air pollution.

Minimise emissions of greenhouse gases to contribute to a reduction and

avoidance of human-induced global climate change.

Reduce waste of energy, and maximise use of renewable energy resources.

Assess, plan and manage adaptation to climate change impacts.

Material Assets 9

10

Maximise the use of the existing built environment.

Avoid flood risk and / or coastal erosion in selecting sites for development.

Cultural Heritage 11 Promote the protection and conservation of the cultural, including

architectural and archaeological, heritage.

Population and

human health

12 Minimise noise, vibration and emissions from traffic, industrial processes and


Soils & Geology 13

14

15

16

Maintain the quality of soils

Give preference to the use of brown field lands, rather than developing

greenfield lands.

Minimise the consumption of non-renewable sand, gravel and rock deposits.


Spatial alternatives in the form of zoning, have been considered for the Wind Energy Strategy. However,

given the range of renewable energy technologies and the county-wide renewable energy resource

potential available, it is considered reasonable to consider non-spatial alteratives for the overall Strategy,

with a focus on written policy, having consideration to the overiding need to support and facilitate

renewable energy development on a county-wide basis accross a wide range of technology potentials. The

alternatives below have been considered on the basis of a strategy for growth for renewable energy.


55

(a) BASELINE SCENARIO – ‘Business as usual’, where all policy measures currently legislated for up

to the end of 20147 are maintained. This could be a future in which no further policy actions or

measures are taken and where renewable energy strategies are not prepared. This would result in

a slow increase in the production of renewable energy however, would fail to meet national 2020

renewable energy targets and would not put in place the economic and societal frameworks

needed to continue renewable energy production to 2030 requirements. Failure to meet legally

binding targets would result in monetary fines and ultimately contribute to unsubstantial reductions

in GHG emissions and poor response to climate change mitigation measures.

(b) NREAP SCENARIO - This scenario is to occur in line with the implementation of the baseline

measures described above and in addition to these, the implementation of the NREAP and White

Paper for Energy 2015 targets and objectives. In addition, the implementation of the National

Energy Efficiency Action Plan 2022 (NEEAP) will achieve lower energy consumption overall due to

energy efficiency measures. This scenario sets out a vision for Tipperary to adopt a planning

framework for renewable energy that facilitates high levels investment across all the renewable

resources including wind, biomass, solar, hydro and geothermal where it can be demonstrated that

environmental impacts are not significant. This scenario is underpinned by Tipperary County

Councils commitment to renewable energy through its membership of the Covenant of Mayors.

Section 5: Evaluation of Alternative Scenarios

The alternatives were assessed against their likely impact on the environment, seven options relating to the

nature of impact envisaged were considered, the options ranged from an ability of the alternative to

improve the environment, to conflict with the environment and to having no significant interaction with the

environment.

Option

Likely to

Improve

status of

SEOs to the

greatest

degree

Likely to

Improve

status of

SEOs to a

greater

degree

Likely to

Improve

status of

SEOs to a

lesser

degree

Least

Potential

Conflict

with status

of SEOs-

likely to be

mitigated

Most

Potential

Conflict

with status

of SEOs-

likely to be

mitigated

Probable

Conflict

with status

of SEOs-

unlikely to

be fully

mitigated

No

significant

interaction

with status

of SEOs

BASELINE

SCENARIO

5, 6, 7, 8,

9, 16

1, 2, 3, 4, 10, 11, 12,

13, 14, 15,

NREAP

SCENARIO

5, 6, 7, 8,

9, 16,

1, 2, 3, 4,

10, 11, 12,

13, 14, 15,

7 Before publication of the White Paper for Energy 2015


56

5.1 Selected Alternative

The alternative selected for the development of the Strategy is Alternative B NREAP Scenario. This

alternative will have the following affects as a result of its implementation and will result in more

environmental benefits than the other alternative examined.

Will reduce all forms of air pollution.

Will minimise emissions of greenhouse gases to contribute to a reduction and avoidance of human-

induced global climate change.

Will reduce waste of energy, and maximise use of renewable energy resources.

Will assist in the planning and management of adaptation to climate change impacts.

Will maximise the use of the existing built environment, and,


At the same time, when compared with the other alternative this option will facilitate the protection and

management of the environment to a greater degree; and resulting in a reduced amount of potential

conflicts. By complying with appropriate mitigation measures - including those which have been integrated

into the Renewable Energy Strategy – potentially significant adverse environmental effects which could

arise as a result of implementing the Strategy would be likely to be avoided, reduced or offset.

Section 6: Mitigation and Monitoring

It was found that the alternative chosen would result in an improvement in certain SEOs and that it also

would have so significant interaction with the environment. Mitigation measures to maintain this finding and

to ensure that the implementation of the Strategy would not result in an impact on the environment are as

follows:

Environmental Protection

Objectives (EPOs)

Mitigation measure proposed

1. Conserve the diversity of

habitats and protected

species

All renewable energy projects proposed will individually be assessed against the

requirements of the Environmental Impact Assessment (EIA) Guidelines and Habitats

Directive and through the EIA and Appropriate Assessment process will be required to

demonstrate that they will not have an adverse impact on any Natura 2000 sites or site

otherwise designated before they will be permitted to proceed. In this respect all new

development in the County must comply with the provisions of the County Development

Plan (as varied) as they relate to Biodiversity, Flora & Fauna . This provision is explicitly

supported by policy RE 1: Protection of the Environment.

In view of the potential for conflict between wind energy development and Natura 2000

sites a detailed SEA and HDA process has been carried out for the Wind Energy

Strategy review. As a precautionary approach and result mitigation measures are

incorporated in the Wind Energy Policy set out in this Renewable Energy Strategy.


57


water use based on long-

term protection of available

water resources.

3. Protect and enhance the

status of aquatic

ecosystems and, with regard

to their water needs,

terrestrial ecosystems and

wetlands directly depending

on the aquatic ecosystems.

Large scale proposals for processing and energy infrastructure will be subject to the

planning process. Key to this process will be an assessment of the environmental

suitably of any site for the development proposed. The Planning Authority will consult

with the EPA and the Department of the Environment, Community and Local

Government along with the other statutory bodies to ascertain whether a development

would have an acceptable impact on the environment.

This Environmental Report has examined the full range of environmental parameters

applicable to the development of renewables and in Section 6.0 of the Renewable

Energy Strategy sets out the policy of the Council with respect the development of

renewable energy projects, this policy will guide and inform the general public and

developers alike with respect the suitability of any site for renewable energy

development in Tipperary.

In this respect all new development in the County must comply with the provisions of

the County Development Plan (as varied) as they relate to water quality and flooding.

This provision is explicitly supported by Policy RE 1: Protection of the Environment.

4. Conserve and enhance

valued natural and historic

landscapes and features

within them.

In view of the potential for landscape change, an independent review of the current

Tipperary Landscape Character Assessments (LCA) was commissioned and this new

review dated 2016 characterises the landscape, identifies sensitivity areas and also set

out guidelines on the capacity of the landscape of the county to accommodate change.

Particular consideration was given to land use types set out across the following

categories: Agriculture and Forestry, Housing, Urbanisation, Infrastructure, Extraction

and energy. Consideration under the energy category was given to solar energy and

wind energy. The RES acknowledges the role of Visual Impact Assessment as a tool to

assist in the assessment of visual impact on the urban and rural environment.

Appropriate planning policy for protection and mitigation measures are incorporated into

the RES in support of the County Development Plan Policy, to avoid conflict with the

EPO for protection of natural and historic landscapes. This is set out in Policy RE2:

Landscape Capacity and Renewable Energy Development.

In applying the Wind Energy policy of the County Development Plan, the Council will

actively encourage developers and investors to engage with local communities to

ascertain their concerns with respect new development, to undertake to address these

concerns where feasible and to consider the setting up of appropriate community

investment funds or schemes that will help to confer a gain to the local community in

areas where it is proposed to install large-scale renewable energy developments. In this

respect, reference should be made to policy RE3: Community Investment in Local

Renewable Energy

In applying the Wind Energy policy of the County Development Plan, the Council will

actively encourage developers and investors to consider the cumulative impact of wind

energy development in areas where wind developments have already been permitted.


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Reference in this respect may be made to the Wind Energy Guidelines 2006 and to the

Scottish Natural Heritage Guidelines - Assessing the Cumulative Impact of on-Shore

Wind Energy Developments 2012.

5. Reduce all forms of air

pollution.


greenhouse gases to

contribute to a reduction and

avoidance of human-


change.

7. Reduce waste of energy,

and maximise use of

renewable energy

resources.

8. Assess, plan and manage

adaptation to climate change

impacts.

All renewable energy projects proposed will be individually assessed against the

requirements of the Environmental Impact Assessment (EIA) Guidelines and the Birds

and Habitats Directive and through the EIA and Appropriate Assessment process will be

required to demonstrate that they will not have an adverse impact on air and climate

before they will be permitted to proceed.

In this respect all new development in the County must comply with the provisions of

the County Development Plan (as varied) as they relate to Air and Climatic factors. This

provision is explicitly supported by Policy RE 1: Protection of the Environment.

The Renewable Energy Strategy is in itself instrumental as part of the process of

climate change adaption as it will facilitate a move away from fossil fuel use with

resultant GHG emissions. This is dealt with in detail in section 1.3 of the Renewable

Energy Strategy.

The Renewable Energy Strategy acknowledges the potential for municipal waste to

contribute to renewable energy production and specially sees a role for Biowaste in the

biomass industry as a feedstock along with agricultural waste. This alternative waste

disposal method will support the SEO relating to minimising the amount of waste to

landfill. In this respect, reference should be made to Policy RE8: Waste to Energy.

9. Maximise the use of the

existing built environment.

10. Avoid flood risk and / or

coastal erosion in selecting

sites for development.

It is recognised that renewable energy infrastructure cannot always be located on lands

that is zoned for industry and employment and in certain cases i.e. in the case of the

development of farm based anaerobic digestion facilities will be appropriately located on

farms and the development of wood chipping facilities will required to be located close

to both wood supplies and to the end-users. This is recognised. However, for very large

scale processing facilities the council will give careful consideration to the ability of the

site to accommodate new development, important considerations will be impact on

infrastructure, water quality, human health etc. Traffic Impact Assessment may be

required as appropriate. In addition to this, the council will also give consideration to the

use of waste heat from energy processes through the use of CHP technologies and

District Heating. In this respect, the location of energy facilities in urban areas where

waste heat can be used in heating systems will be encouraged. Reference should be

made to Section 6.6.1 Bioenergy Development in Tipperary.

The minimisation of flood risk continues to be an important consideration of the Council

and in assessing any planning application the planning authority will have consideration

to flood risk potential. Flood risk mapping as currently available and that will be

available through the OPW CFRMPS will be applied. Flood Risk Assessment may be

required where appropriate

11. Promote the protection In respect to this SEO all new development in the County must comply with the


59

and conservation of cultural

assets, including

architectural, archaeological

and heritage.

provisions of the County Development Plan (as varied) as they relate to Cultural

Heritage. New development proposals will be assessed for compliance with the polices

and objectives of the County Development Plan as set out in Chapter 7. Particular

reference should be made to the following policies:

Policy LH13: Protected Structures

Policy LH14: Architectural Conservation Areas

Policy LH15: Architectural Heritage of Local Interest

Policy6 LH16: Archaeology and Cultural Heritage

12. Minimise noise, vibration

and emissions from traffic,

industrial processes and


In respect to this SEO, all new development in the County must comply with the

provisions of the County Development Plan (as varied) as they relate to Development

Management Standards for new development. New development proposals will be

assessed for compliance with the policies and objectives of the County Development

Plan as set out in Chapter 10. In addition, the appropriate government guidance will be

applied to all new development.

13. Maintain the quality of

soils

14. Give preference to the

use of brown field lands,

rather than developing

Greenfield lands.

15. Minimise the

consumption of non-

renewable sand, gravel and

rock deposits.

16. Minimise the amount of

waste to landfill.

In respect to this SEO, all new development in the County must comply with the

provisions of the County Development Plan (as varied) as they relate to Development

Management Standards for new development. New development proposals will be

assessed for compliance with the policies and objectives of the County Development

Plan as set out in Chapter 10. In addition, the appropriate government guidance will be

applied to all new development.

In addition, this Strategy notes the potential for waste material such as organic waste to

contribute as a feed stock to energy recovery process such as anaerobic digestion.

Reference should be made to Policy RE8: Waste to Energy.

Article 10 of the SEA Directive requires Member States to monitor the significant environmental effects of

the implementation of plans “in order, inter alia, to identify at an early stage unforeseen adverse effects and

to be able to undertake appropriate remedial action.”

The monitoring programme for the Renewable Energy Strategy is set out, and in respect of each SEO

indicators of environmental change are identified and targets are thereafter set out. The success of the

implementation of the Strategy will be based on whether or not these targets have been achieved.

A stand-alone Monitoring Report on the significant environmental effects of implementing the County

Development Plan (including the Renewable Energy Strategy) will be prepared in advance of the review of

the County Development Plan.

strategic environmental assessment and · strategic environmental assessment (sea), to determine...

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