This submission to the public consultation on the Grid Link project proposes that there are fundamental flaws in the EirGrid argument and approach.
This submission will outline concerns with both the proposed scope and the underlying political and policy approach taken by the Government which supports EirGrid’s plans. This submission will also outline concerns about the lack of proper environmental impact assessment (EIA) in advance of deciding any of the proposed Grid Link routes; the lack of EIA underpinning Grid 25 and the Government’s National Renewable Energy Action Plan; and the lack of proper assessment or analysis of the economic and social impact of the Government’s planned energy export infrastructure development. Finally, this submission highlights what appears to be a lack of concern displayed by the Government regarding the health impacts of living close to overhead pylons.
“The Grid Link Project is an estimated €500 million investment in the national electricity grid linking Leinster and Munster. The project consists of a new high voltage overhead power line linking Knockraha in Co. Cork to Great Island in Co. Wexford to Dunstown, near Kilcullen, in Co. Kildare ensuring a reliable and high-quality electricity supply for homes, farms and businesses in the south and east region for the future.
It is a vital development for the region and will deliver a wide range of benefits including:
• Helping to secure a future electricity supply for Leinster and Munster
• Providing a platform for job creation in the south and east of Ireland
• Helping to enable Ireland meet its 40% renewable electricity target
• Facilitating possible electricity links with either Britain or France.” 
EirGrid claims that Grid Link will help Ireland meet its 40% renewable electricity target and facilitate possible electricity links with Britain or France.
Grid 25 underpins government policy of developing wind energy for export. While being a strong advocate and supporter of Ireland reaching its renewable energy targets, I believe current and previous government policy has been too focused on wind development to the detriment of achieving more sustainable energy conservation targets and a wider selection of alternatives such as biomass and solar.
As regards energy conservation policy, the Irish Academy of Engineers has produced a comprehensive report ‘Achieving Ireland’s Energy and Co2 reduction targets’, which outlines efficient and achievable conservation targets.
However, in my opinion introducing any large scale development in Ireland, such as Grid 25, and wind/wave renewable energy projects, is problematical because of poor and inadequate environmental impact assessments, and lack of marine spatial planning legislation. Planning problems associated with wind farm developments are succinctly summed up by the Friends of the Irish Environment in their response to the Government’s draft revised wind farm guidelines .
Lack of compliance with criteria for EU funding for TEN-E projects
Although the proposed Grid Link project will not be directly grant-aided by the EU, the network would be inextricably linked with Irish projects listed as trans-European network projects (TEN-E). This is because the entire grid is in a permanent state of connection at all times, and one piece can’t exist in isolation from all the others. For example, item 1 on the Irish TEN-E list quoted in my communication with the EU Commission ‘A new HVDC subsea connection of approximately 600km with a capacity of around 700 MW between Ireland and France’, could not happen without strengthening the domestic grid into and out of Great Island power station in Co. Wexford, as proposed under the Grid Link project.
In a detailed letter to the EU Commissioner for Energy, I asked that the Commission ensure that EirGrid and the Government fully comply with the socio-economic and environmental criteria recently established by the EU for the approval and funding of major electricity projects. I have asked for the Commissioner’s assurance that the Commission will insist on full compliance in this area from the Irish authorities. The criteria for funding is set out in the Commission Decision of 29th October 2012 establishing the 2013 annual work programme for granting financial aid in the field of trans-European networks (TEN).
The Grid Link projects should be subject to similar criteria, and it is incumbent on the Government to publish transparent and independently audited assessment of the economic and social impacts of the TEN-E projects and all association grid networks proposed for development in Ireland. That this would involve the Government drawing up an approved programme for evaluation of the socio-economic and environmental effects of these projects, in consultation with affected stakeholders. In preparing such evaluations, they should prioritise those projects that are in the early stage of the public planning and permitting process.
In my letter to the Commissioner I said that I wished ‘to convey to you the extreme concern of many of my constituents, and my own concern, in relation to the manner in which these projects are being progressed by the Irish authorities… the Irish authorities have made no real attempt to progress these energy projects in a manner consistent with meeting the Commission’s criteria of evaluating their socio-economic and environmental effects.’
For example, it is of extreme concern that EirGrid and private sector companies are rapidly moving the proposed interconnector between counties Meath and Tyrone and the wind farm projects in the Midlands to the public planning approval and permitting stage, and it appears that the same approach is being applied to the Grid Link project proposed for Leinster and Munster.
Critically in my opinion, EirGrid has not in any way complied with EU Directive 2011/92/EU on the assessment of the effects of certain public and private projects of December 2011. Although there have been claims of consultation, the public are being presented with Grid Link routes and are being asked for their feedback.
But this directive obliges developers of both private and public projects that are likely to have to have significant effects on the environment to undertake an assessment of the likely significant environmental effects of these projects, before any consent can be granted. The effects of a project on the environment should be assessed in order to take account of concerns to protect human health, to contribute by means of a better environment to the quality of life, to ensure maintenance of the diversity of species and to maintain the reproductive capacity of the ecosystem as a basic resource or life. As part of this assessment, effective public participation in the taking of decisions is required, in this process the public should be given an opportunity to express their concerns and opinions about the projects is required. The decision-maker should take account of opinions and concerns which may be relevant to those decisions, thereby increasing the accountability and transparency of the decision-making process and contributing to public awareness of environmental issues and support for the decisions taken.
This has not happened, instead the public are being presented with a fait accompli, with the only decision being which route rather than what is the best solution to protect Ireland’s energy needs, and protect landscape, environment, public health and the local economy.
Flaws underpinning Grid 25 strategy
The Government is proceeding with a National Renewable Energy Action Plan (NREAP) involving some 3,000 wind turbines and 5,000km of high voltage lines (Grid 25), with both strategies going ahead under inadequate public consultation and underpinned with the weak planning infrastructure underlined above. The Grid Link network is a critical component of both these strategies, and to proceed without open transparent and adequate environmental and socio-economic analysis is of concern to say the least.
Community groups and interested individuals have raised well researched questions around the necessity for a further 5,000km of high voltage lines in Ireland, the cost of which will have to be most likely be borne by the Irish citizen. Furthermore, in its submission on the potential for large scale energy exports from Ireland, the Irish Academy of Engineers highlights planning and cost benefit problems which would need to be questioned and addressed if the Government is to proceed with major energy infrastructure.
Health effects of electric and magnetic fields associated with extra high voltage lines and the need for high power electric cables to go underground
Finally, this submission deals with the critical issue of health and the effects of electric and magnetic fields associated with extra high voltage lines. A significant body of research over the years has been performed in relation to the health effects of electric and magnetic fields associated with extra high voltage lines and I quote from NEPP briefing document: ‘Current scientific data now confirms that exposure to electromagnetic fields (EMF) above 0.4 microteslas increases the risk of leukaemia, particularly for children. Additionally, increasing evidence shows that it is associated with an increased risk of miscarriage, brain tumours, Alzheimer’s and motorneurone disease.’. In the face of current research, for the Government to consistency claim that there are no health risks is callus and careless in the extreme. As a matter of urgency the cost of laying underground cables must a key component of grid any expansion plans.
It is very important that there is an independent and fully transparent cost benefit analysis of the need to radically expand the national grid, including the need for more wind energy and the need to export wind energy to the UK or France. We also need to undertake a cost benefit analysis of running the lines underground, without any associated scaremongering of people in advance. These analyses and evaluations must include what is called the ‘public good’, that is the local economy, tourism, protecting Ireland’s wonderful landscapes, and our future energy needs.
Local people must be respected and listened to, and their ability to live in the comfort of their homes fully protected by the state.
Nessa Childers MEP, 7th January 2014.
Phone: 01 296 2263 / 00 32 2 284 5535 (Brussels)
Email: firstname.lastname@example.org / email@example.com
Full text of letter from Nessa Childers MEP to EU Energy Commissioner, Günther Oettinger, 26th November 2013 regarding ‘Energy Projects of Common Interest involving Ireland’
I refer to the Commission Decision C(2012)7510 of 29/10/2012 establishing the 2013 annual work programme for granting financial aid in the field of trans-European networks (TEN) – area of energy infrastructures (TEN-E). Annex I of the Decision, in paragraph 9, sets out the award criteria for inclusion and approval of projects under the programme. These include, inter alia, the following criteria:
I further refer to the list of 248 Projects of Common Interest (PCI) in the energy field adopted by the Commission on 14th October 2013 and, in particular, to the Overview of projects by country published on the same date. In respect of Ireland, this Overview includes, inter alia, the following significant electricity projects:
A new HVDC subsea connection of approximately 600 km with a capacity of around 700 MW between Ireland and France.
Around 40 individual onshore wind farms, totalling 3 GW collected together through an underground private network in the midlands of Ireland, connected directly to the UK national grid via two 600 kV HVDC sub-sea cables of approximately 500 km and with a capacity of 5 GW in Wales (onshore and offshore).
An offshore interconnected electricity grid based on renewable resources (wind, wave and tidal connecting 3200 MW) consisting of 850 km of HVDC interconnectors with a capacity of 500-1000MW in the northern area (offshore).
Energy Bridge (EB) HVDC underground cable of +/- 320kV for the 1st circuit and +/- 500kV for 2 and 3, respectively, and with a total capacity of 5 GW. The length of the 3 circuits will be 290 km, 190 km and 129 km, respectively. The cable will route large amounts of renewable electricity generated in a series of interconnected Irish wind farms directly into the UK market (onshore and offshore).
Large Scale Hydro Storage facility in the North West of Ireland with a daily capacity of 90 GWh (32850 GWh annually).
A 320-400 kV HVDC underground cable interconnection of approximately 450km and with a capacity of 1200 MW between the North West of Ireland and the UK Midlands (onshore and offshore).
Combined 1900 MW wind generation, with a 6.1 GWh (2226.5 GWh annually) storage in Glinsk, county Mayo.
A 500kV HVDC VSC cable of 530 km (subsea Atlantic 75, cross country Ireland 222 km, Irish Sea approx. 230 km, 1-3 km onshore Pembroke) with a capacity of 1300 MW, connecting the combined wind generation and storage facility in Glinsk, county Mayo to Deeside in the UK (onshore and offshore).
A new 400 kV AC single circuit (OHL) of 140 km and with a capacity of 1,500 MVA between Turleenan, county Tyrone 400/275 kV in Northern Ireland (UK) to Woodland, county Meath 400/220 kV (IE) (onshore).
A new 275 kV and partly 220 kV AC cross border circuit (OHL) of 196 km and with minimum capacities of 710 MVA and partly 431 MVA between Srananagh 220 kV station in county Sligo and Turleenan 400/275 kV station in Northern Ireland (UK) that will facilitate the integration of a planned wind generation of approximately 768 MW, which equates to 0.1 GW/1000km² (onshore).
Physical reverse flow at the Moffat interconnection point, which is currently uni-directional, supporting forward flow only from UK to Ireland, the Isle of Man and Northern Ireland (onshore). The planned capacity is 38.5 GWh/d.
I wish to convey to you the extreme concern of many of my constituents, and my own concern, in relation to the manner in which the above mentioned projects are being progressed by the Irish authorities, notably the Transmission System Operator (TSO) EirGrid plc (which is entirely owned by the Irish State), under the oversight of the Department of Communications, Energy and Natural Resources.
Projects nos. 2 and 9 listed above are being moved rapidly to the public planning approval and permitting stage by the TSO and / or private sector companies
a) without any proper consultation with stakeholders in the affected communities,
b) without adequate assessment of their environmental effects and,
c) without any assessment whatsoever of their socio-economic effects, including – for example – devaluation of farms and homes, loss of earnings in agriculture, tourism, negative effects on areas of natural or heritage conservation and public health.
The majority of the projects I have listed above have not even been put into the public domain by the TSO and citizens are completely in the dark in relation to the full, radical extent of their proposals. The Irish authorities have made no real attempt to progress these projects in a manner consistent with meeting the Commission’s criteria of evaluating their socioeconomic and environmental effects.
As you are aware, the Commission has indicated publicly that it ‘will monitor closely the implementation of the permit granting measures and the construction of the projects.’ Furthermore, the Commission has stated that‘Competent authorities have to publish a manual of procedures for the permit granting process and make it available to the public. In compliance with this manual, project promoters will have to submit a concept for public participation to the authorities’.
I request your assurance that the Commission will insist on full compliance by the Irish authorities with the criteria for funding set out in paragraph 9, Annex I of Commission Decision C(2012)7510 of 29/10/2012 establishing the 2013 annual work programme for granting financial aid in the field of trans-European networks (TEN) – area of energy infrastructures (TEN-E).
Accordingly, I am asking you to confirm to the Irish authorities that none of the projects I have listed above will be considered for support under the annual work programme for granting financial aid in the field of trans-European networks (TEN), unless they have submitted to you, and published, an approved programme for evaluation of the socioeconomic / environmental effects of these projects, in consultation with affected stakeholders. In preparing such evaluations, they should prioritise those projects that are in the early stage of the public planning and permitting process, that is, the projects numbered 2 and 9 above.
I have no doubt that, in the interests of economic development, the vast majority of my constituents favour appropriate reinforcement of the national grid as well as a programme of adoption of renewable energy sources that is consistent with our national needs. However, there is widespread anger and opposition to these projects throughout Ireland because of the failure of the TSO and the Department of Communications, Energy and Natural Resources to consult stakeholders properly, failure to consider means of ultra high voltage transmission other than overhead lines carried on pylons and failure to comply with the criteria set out in the Commission decision of 29/10/2012.
Unless you, as the Commissioner responsible, make a decisive intervention, such as I am suggesting, there is a grave danger that that these projects will be halted for years or totally jeopardised, to the detriment of both Ireland and the European Union.
Nessa Childers MEP
(Member of the Environment, Public Health and Food Safety Committee)
4 December 2013 – Written question P-13577/13 (Childers) – Application Annex III (1)
Directive 2011/92/EU on the assessment of the effects of certain public and private projects of December 2011, obliges developers of both private and public projects that are likely to have to have significant effects on the environment to undertake an assessment of the likely significant environmental effects of these projects, before any consent can be granted. The effects of a project on the environment should be assessed in order to take account of concerns to protect human health, to contribute by means of a better environment to the quality of life, to ensure maintenance of the diversity of species and to maintain the reproductive capacity of the ecosystem as a basic resource or life. As part of this assessment, effective public participation in the taking of decisions is required, in this process the public should be given an opportunity to express their concerns and opinions about the projects is required. The decision-maker should take account of, opinions and concerns which may be relevant to those decisions, thereby increasing the accountability and transparency of the decision-making process and contributing to public awareness of environmental issues and support for the decisions taken. EirGrid, Ireland’s state owned electricity provider is planning Grid Link projects that include corridors of overhead pylons across land-mass of the Republic of Ireland, as well as developing around 40 individual onshore wind farms. These projects are included in the list of 248 Projects of Common Interest (PCI) in the energy field adopted by the Commission on 14th October 2013. These projects fall under category of a project that is likely to have a significant effect on the environment. Can the Commission confirm that these projects underwent the necessary assessment required under this directive?
Nessa Childers MEP