‘As Ireland’s one Full Member of the European Parliament’s Environment, Public Health and Food Safety Committee, I wish to convey to you the extreme concern of many of my constituents, and my own concern, in relation to the manner which the government is implementing national and trans-regional energy projects and policies’
Mr. Pat Rabbitte, Minister for Communications, Energy & Natural Resources Department of Communications, Energy and Natural Resources, 29-31 Adelaide Road, Dublin 2, Ireland
23rd January 2014
Dear Minister Rabbitte,
As Ireland’s one Full Member of the European Parliament’s Environment, Public Health and Food Safety Committee, I wish to convey to you the extreme concern of many of my constituents, and my own concern, in relation to the manner which the government is implementing national and trans-regional energy projects and policies.
• Projects of Common Interest
Projects of Common Interest (PCI) in the energy field adopted by the Commission on 14th October 2013 are being progressed in Ireland, notably the Transmission System Operator (TSO) EirGrid plc under the oversight of the Department of Communications, Energy and Natural Resources.
In a detailed letter to the EU Commissioner for Energy Commissioner Günther Oettinger dated the 26th November 2013, I asked that the Commission ensure the Irish 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 asked for the Commissioner’s assurance that the Commission will insist on full compliance in this area from the Irish Authorities.
In the response dated the 15th January 2014 Ms. Catharina Sikow, Head of the Internal Market I: Networks & Regional Initiatives Unit, on behalf of Commissioner Oettinger has stated that those Irish projects which are not compliant will not receive financial aid:
‘The PCI’s were selected according to criteria defined in Article 4 and Annex IV of the Infrastructure Regulation. During the selection process the projects were assessed regarding their contribution from the perspective of the European energy policy. The inclusion of projects in the Union list of PCIs is without prejudice to the outcome of relevant environmental assessment and permitting procedures carried out by the national permitting authorities. Projects not in compliance with Union legislation should be removed from the Union list of PCIs (Art. 5 paragraph 8 of the Infrastructure Regulation).
The Infrastructure Regulation foresees a monitoring of the PCIs according to article 5. The monitoring of all projects, including the Irish PCIs, will be carried out by the regional Groups. According to Art. 5 Paragraph 5 the competent authorities have to report to the regional Group on the progress achieved in project implementation and we will certainly closely follow all activities related to the implementation of the mentioned Irish projects. The Irish projects which are not compliant with environmental law will be removed from the Union wide PCI list and will not be able to receive any financial aid.
A good communication between the project promoters, authorities and stakeholders is one of the main pillars for the successful implementation of infrastructure projects and I agree that there is an urgent need for improvement. The Infrastructure Regulation defines in Article 9 and Annex VI the requirements for transparency and public participation. Especially Article 9 paragraph 7 obliges the project promoter respectively the national authority to establish and regularly update a website with relevant information about the PCI. The European Commission will follow the fulfilment of this obligation.
…. I would like to thank you for pinpointing the critical issues for the Irish PCI’s and would like to reassure you that the European Commission will continue closely follow the implementation of the obligations defined in Infrastructure Regulation.’
This highlights once again that lack of transparency and proper public consultation can create a detrimental impact on our country’s ability to secure energy funding. Rigorous Environment Impact Assessments and properly informing the public about these major projects is paramount. In my opinion, introducing any large scale development in Ireland 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 .
While not being directly funded by the European Commission, the Gridlink Project is intrinsically linked with all the other projects in TEN-E. The entire grid is in a permanent state of connection at all times and one piece cannot exist in isolation from all the others. For example ‘A new HVDC subsea connection of approximately 600 km 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 County Wexford – which is one of the things proposed under Gridlink Project
Could you also confirm that the Gridlink project is a point-to-point connection project and there will be no intermediate connections on the new routes at later dates- as the implications are more than merely operational and as such, one that the Department of Communications, Energy and Natural Resources, is likely to refer to Eirgrid. I would appreciate your Departments policy position regarding this issue as it is of considerable concern to many citizens living in south and south east Ireland.
• Transparency and Consultation
As part of this assessment, effective public participation in the taking of decisions is required to increase the accountability and transparency of the decision-making process and contribute to public awareness of environmental issues and support for the decisions taken.
It is of extreme concern for example, 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 have been 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.
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 unacceptable.
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.
Currently, there are 4 lines serving the south east of the country; 2 x 220kV lines and 2 x 110kV lines. There are a further 2 lines supplying the mid-south area, both 110kV. In the interest of transparency, could you please furnish me with the daily load graphs so that a transparent assessment of the capacity of these lines may be undertaken?
Could you also please confirm that the Gridlink project is a point-to-point connection project and there will be no intermediate connections on the new routes at later dates? I believe that this is a matter of national policy rather than operational and as such request clarification from your Department.
Furthermore, with reference to 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 .
The critical issue of health and the effects of electric and magnetic fields associated with extra high voltage lines cannot be overlooked. 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 North East Pylon Pressure (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 motor neurone disease.’ .
• European Commission’s 2030 Climate and Energy Goals
With reference to the European Commission’s 2030 climate and energy goals for a competitive, secure and low-carbon EU economy announced as of the 22nd January 2014, I would like to draw your attention to the following key elements of the policy framework.
An EU-wide binding renewable energy target: Renewable energy will play a key role in the transition towards a competitive, secure and sustainable energy system. Driven by a more market-oriented approach with enabling conditions for emerging technologies, an EU-wide binding target for renewable energy of at least 27% in 2030 comes with significant benefits in terms of energy trade balances, reliance on indigenous energy sources, jobs and growth. An EU-level target for renewable energy is necessary to drive continued investment in the sector. However, it would not be translated into national targets through EU legislation, thus leaving flexibility for Member States to transform the energy system in a way that is adapted to national preferences and circumstances. Attainment of the EU renewables target would be ensured by the new governance system based on national energy plans.
• Memorandum of Understanding and Inter-Governmental Agreement with the United Kingdom
I believe that now is the time to review the Memorandum of Understanding signed with the United Kingdom in January 2013, which commits Ireland and the United Kingdom to conducting an evaluation of how Irish renewable energy resources can be developed for the mutual benefit of both countries in line with relevant EU Directives, including Directive 2009/28/EC. Furthermore, I do not believe that an Inter-Governmental Agreement can now be entered into. The Government’s plans to export energy to the United Kingdom to facilitate the meeting of binding renewable energy targets may become a moot point- demand may not meet supply
While I support the Government’s commitment to renewable energy, I believe the following actions are of importance to ensure that Ireland progresses its energy policies in the best interests of the Irish citizens and in order to reach our climate change obligations in a sustainable manner:
• That the Irish government carry out a rigorous transparent cost- benefit analysis to identify our true indigenous energy requirements, also demonstrate clearly our need to export energy, and to whom this energy will be sold.
• The protection of our natural environment, heritage and local economies must now be recognised as of primary importance. This must include the adoption of a comprehensive marine spatial planning to protect our marine environments and coastal communities as blue energy technology development advances.
• That the National Landscape Strategy be implemented urgently with the support of your Department as a member of the Steering Group. In line with our signing and ratification of the European Landscape Convention in 2000, Ireland made a commitment to deliver a National Landscape Strategy which is now long overdue.
Nessa Childers MEP
Member of the European Parliament Environment, Public Health and Food Safety Committee
European Parliament, ASP 22G 215, Rue Wiertz 60, Brussels, Belgium