1. Does Blue Ireland support the transition from fossil fuel generated energy to renewables, including offshore renewables?

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

2. Why does your organisation exist?

Blue Ireland exists to advocate for proper Marine Spatial Planning (MSP) and appropriate siting of offshore renewable energy (ORE) developments in order to optimise benefits (e.g., carbon capture and fish stocks) and minimise damaging impacts on the marine environment (e.g., damage to ecosystems and biodiversity). The issue is that, as a result of lax permitting regimes, at present all ORE projects in Ireland are proposed on sites self-selected by developers, with no regard for environmental impacts on marine life, livelihoods, or the Irish coastline.

3. How has the government managed the offshore wind permitting process?

The legislation governing construction at sea is The Foreshore Act 1933. This law gives power to a Minister to grant foreshore licences (for site investigation) and leases (for construction) for proposed offshore projects. It has been used by successive Ministers over the past 25 years to give consent to prospective offshore wind developers who selected areas of the foreshore (out to 12 nautical miles or 22.2 km) on a ‘first-come-first-served’, ad hoc, basis, with no environmental constraints. The consequences of this developer-led planning and lax regulation are widespread, posing a significant threat to valuable marine habitats and species and the democratic process. Firstly, many current development proposals are targeting high biodiversity value sites that are, in fact, completely unsuitable for development. See the Fair Seas report ‘ Revitalising our Seas ’ for further details. Secondly, over the past decade, most of the original stakeholders have sold on all or part of their dubious interests, netting them large profits in return for access to State-owned foreshore. In February 2020, for example, it was reported that French Energy giant, EDF, acquired a 50% stake in the proposed Codling windfarm from a company linked to developer, Johnny Ronan, at an estimated cost of €100 million. Just months earlier, in June 2019, official documentation shows that €5m was owed by Codling in unpaid fees to the State, that it was considered that Codling was close to being in development default and that the Department was contemplating termination of the lease. By 19 May 2020, all this changed. It was announced that Codling had been classified as a ‘relevant’ project, and would be fast-tracked through the consenting process. Unbelievably, all this happened in the absence of any environmental assessment or public involvement, at a time when the country was experiencing the early chaos of the Covid pandemic.

4. Why are so many current applications for offshore wind being challenged through Judicial Review?

Sites on which major developments are now proposed were selected more than 20 years ago on a first-come-first served basis, in the absence of any environmental safeguards. They were not selected based on where sustainable development could take place, but on the technology available at the time. In the intervening years, offshore wind technology has changed immeasurably. Developments no longer need to be sited in shallow water and the advent of floating wind has created the potential to site turbines further out to sea, where winds are stronger and where the worst impacts of developments on sensitive coastal waters can be mitigated. Because of this historic mis-management, the reality is that, in spite of intensive efforts by government to chart a pathway to completion for these legacy projects, because they are effectively the wrong developments in the wrong places, many are being challenged through Judicial Review. Not alone is this extremely costly for the State (essentially the tax-payer) it means that (1) whether or not these...

5. What is marine spatial planning (MSP) and in what way would Marine Spatial Planning help?

Marine Spatial Planning (MSP) is defined as ‘a process by which the relevant Member State’s authorities analyse and organise human activities in marine areas to achieve ecological, economic and social objectives’ (EU, 2014). The European Union (EU) Maritime Spatial Planning Directive (2014) required all Member States with marine territories to prepare ecosystem-based maritime spatial plans for their waters by March 2021. This approach allows for maximising the benefits of our seas, while minimising the harm to our coastal habitats in order to ensure that the common good is served.

6. What does ecosystem-based mean?

Ecosystem-based planning seeks to identify and understand the important ecological characteristics of an area, and then to design plans to guide the development of ecologically responsible human activities in that space. Ecosystem-based planning focuses on the diverse benefits provided by functioning marine ecosystems, rather than on single species, habitat or ecosystem service. An ecosystem-based approach ensures that the protected species, habitats and the unique ecosystems that support them are maintained. All such species/habitats are interconnected and cannot be considered independently. Such benefits or services include vibrant commercial and recreational fisheries, biodiversity conservation, renewable energy from wind or waves and coastal protection. Of the four factors listed here, biodiversity conservation, inshore fisheries and coastal protection are threatened by the development of current Irish government plans for coastal offshore wind development.

7. So, did Ireland prepare a Maritime Spatial Plan?

Ireland, like other EU countries, was obliged to prepare an ecosystem-based spatial plan by March 2021 but, unfortunately, the plan developed by Ireland does not comply with the EU MSP Directive. The National Marine Planning Framework (NMPF) adopted by the Irish Government in May 2021 is not ecosystem-based. It provides a policy framework for marine planning but does not specify where activities will take place at sea or set out regionally differentiated priorities for the use and protection of Ireland’s marine space ( Walsh, 2022 ). The NMPF, therefore, fails to meet the core requirements of the EU MSP Directive and cannot be considered as a marine spatial plan.

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

Regulation of offshore wind development varies throughout the world. This is sometimes justified with claims that the sector is nascent, i.e., emerging, and consequently some countries are only in the process of developing policy. However, much of Ireland’s environmental law is grounded in long-standing EU laws and Directives which are applicable within individual Member States. This includes the Marine Strategy Framework Directive (2008/56/EC), the Birds Directive (2009/147/EC), the Habitats Directive (92/43/EEC), the Strategic Environmental Assessment Directive (2001/42/EC), the Environmental Impact Assessment Directive (2011/92/EU), and the EU Maritime Spatial Planning Directive (2014/89/EU). Ireland has continued to process applications for offshore wind without regard to a number of these Directives. This failure to comply with the Directives has resulted, on a number of occasions, in Ireland being found to be in breach of EU law, the most recent judgement against Ireland made on 30 June 2023. A comprehensive briefing note prepared by Coastal Concern Alliance outlines the diverse consenting processes for ORE in different EU countries.

9. Are you simply arguing for biodiversity protection as a way of rejecting development of all offshore wind?

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

10. In what way could offshore wind development have negative impacts on our seas?

Site-selection is internationally accepted as the most important factor in mitigating the biodiversity impacts of wind and solar developments. To-date, in Ireland, site-selection for offshore wind development has been exclusively developer-led, with no government oversight or Strategic Environmental Assessment (SEA) to assess cumulative impacts, as is required under the SEA Directive. People may imagine that the seabed around our coast consists of sand; in fact, it consists of so much more, with rocky terrains and glacial deeps, biogenic reefs (made by living organisms) and geogenic reefs (resulting from geological processes) all hosting a huge diversity of life forms. Information shown on NASA maps indicates the dense concentrations of phytoplankton that skirt Ireland’s coast. Phytoplankton, essential to our survival, is arguably the most important life on earth . It produces more than 50% of the earth’s oxygen through photosynthesis and is highly effective at absorbing carbon from the atmosphere. Phytoplankton are the foundation of the aquatic food web, the primary producers, feeding everything from microscopic, animal-like zooplankton to multi-ton whales. Small fish and invertebrates also graze on the plant-like organisms, and, in turn, smaller animals are eaten by bigger ones. The presence of these microscopic creatures explains the rich biodiversity that we in Ireland enjoy in our coastal waters. In fact, our seas and sea beds contain Ireland’s most pristine functioning ecosystems. Though overfishing has had impacts, vast areas of undamaged seabed remain intact, in stark contrast to our lands, where almost every inch has been impacted by human disturbance. Mudflats and sandflats, for example, not only host biodiverse habitats, they are also a really effective carbon sink. Seagrass meadows, found dotted around the Irish coast, stabilise the sea floor and can absorb carbon 35 times faster than the Amazon rainforest. Because of developer-led planning, many proposed wind developments are sited where their construction, and even initial site investigations, have the potential to have significant negative impacts on some of these important marine ecosystems. Current development proposals traverse or adjoin many important ecologically valuable areas, Special Areas of Conservation (SAC), designated to protect marine habitats such as reefs, seagrass and sandbanks, and Special Protection Areas (SPA), to protect rare seabird species such as terns, puffin and kittiwakes. Siting of developments in close proximity to these protected areas poses an unnecessary risk to Ireland’s biodiversity, threatened species and habitats. Until a few months ago, just 2.1% of Ireland’s maritime area was even nominally protected in SACs and SPAs although our target was to have 10% fully protected by 2020 and by 2030, 30% of the marine area should be designated and managed to ensure it is truly safeguarded. Some progress is being made but, in the meantime, Blue Ireland believes that it is vital that we value all rich marine habitats and species because the future of the planet, and our future, depends on it. With regard to the areas which Ireland has designated as SACs and SPAs, the Irish government has consistently failed to fulfil their obligations and adequately protect those areas, resulting, on a number of occasions, in Ireland being found to be in breach of EU law, with the most recent judgement against Ireland being handed down on 30 June 2023. Poorly sited wind farms can have a detrimental effect on healthy marine ecosystems. The failure of the government to adequately manage site-selection, as well as substantial delays in designation of Marine Protected Areas means that currently proposed offshore wind developments pose a serious threat to Ireland’s marine biodiversity, with knock-on effects for natural carbon capture.

FAQs Archive - Blue Ireland

Published: September 2, 2023

1. Does Blue Ireland support the transition from fossil fuel generated energy to renewables, including offshore renewables?
Learn More
Published: July 2, 2023

2. Why does your organisation exist?
Learn More
Published: July 2, 2023

3. How has the government managed the offshore wind permitting process?
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Published: July 2, 2023

4. Why are so many current applications for offshore wind being challenged through Judicial Review?
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Published: June 20, 2022

5. What is marine spatial planning (MSP) and in what way would Marine Spatial Planning help?
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Published: June 20, 2022

6. What does ecosystem-based mean?
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Published: June 20, 2022

7. So, did Ireland prepare a Maritime Spatial Plan?
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Published: June 20, 2022

8. Regarding offshore wind development and EU best practice, where does Ireland fit in?
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Published: May 31, 2022

9. Are you simply arguing for biodiversity protection as a way of rejecting development of all offshore wind?
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Published: April 20, 2022

10. In what way could offshore wind development have negative impacts on our seas?
Learn More