SOUTH EAST COASTAL PROTECTION ALLIANCE
South East Coastal Protection Alliance is a voluntary group composed of local residents and concerned individuals, who are worried about the possible devastating impact that developing a wind farm on the Arklow Bank and other sand banks along the South-East coast will have on the coastal environment. This is an environmental conservation organisation.
€2.5 BILLION WINDFARM vs WICKLOW & WEXFORD BEACHES
WHY CAN’T WE HAVE BOTH?
SECPA supports Off-Shore Wind Parks but not Near-Shore Wind Parks constructed on sandbanks within the most fertile area of the sea. These should be located further out to sea at least 22km.
An Bord Pleanála has now received an application from SSE renewables (Sure Partners) for permission to construct a Wind Farm on the Arklow Sandbank.
There are two proposals, Option 1 is for 56 turbines 273m high (900ft) and Option 2 is for 46 turbines 287m high (940ft). Both options require two offshore platforms (OSPs) for electricity sub-stations to be constructed.
We believe that the solution is to move the Wind Farm away from the sandbanks and away from the coast and not located in the most fertile areas of the sea. This is technically and commercially possible and is in use elsewhere in the world.
We believe that this application is fundamentally flawed, the project is too big and too close and not located on an environmentally suitable site.
Damage that will be caused to the sandbank by the construction of this industrial development we believe will devastate the sandbank and cause irreparable damage to the coast by substantially increasing the rate of erosion and will cause an environment disaster. In particular, to the sand dunes at Brittas Bay Beach which are under threat of destruction.
The close distance of 6km to 15km proposed by the Developers of the Arklow Bank Wind Park 2 (ABWP2) would not be permitted elsewhere in the EU. No other country in Europe would allow a Wind Park of this magnitude so close to shore, on a conservation site in an area of outstanding natural beauty.
WHY THIS IS A BAD IDEA
While some people may regard such turbines as benign features on the seascape, the following stark details have been gleaned from data provided by SSE in their own application.
CONCERNS WE HAVE
We believe that this application is fundamentally flawed, the project is too big and too close and not located on an environmentally suitable site.
Damage that will be caused to the sandbank by the construction of this industrial development we believe will devastate the sandbank and cause irreparable damage to the coast by substantially increasing the rate of erosion and will cause an environment disaster. In particular, to the sand dunes at Brittas Bay Beach and at other beaches along the coast are under threat of destruction.
The close distance of 6km to 15km proposed by the Developers of the Arklow Bank Wind Park 2 (ABWP2) would not be permitted elsewhere in the EU. No other country in Europe would allow a Wind Park of this magnitude so close to shore, on a conservation site in an area of outstanding natural beauty.
Damage to the Sandbank will cause the very strong tidal forces to be changed with unforeseen negative consequences on the coast. The rate of coastal erosion will increase as a result.
THE PROPOSED TURBINE PLAN
MAP OF ARKLOW WIND PARK 2
Detrimental effect on the environment
THE IMPACT
The Arklow sand banks have been formed over millennia by sand being carried up the east coast of Ireland, deposited on sandbanks and forming the beaches and sand dunes. The sandbanks form a buffer against tides, storms and rising seas. They also are central to replenishing the sand on our beaches along the south east coast. If wind turbines are erected on these sandbanks, we believe they will seriously interfere with this natural process and lead to the decimation of beaches and sand dunes.
SECPA is in favour of wind energy as a renewable source but object to these proposed projects on the sandbanks and believe that, while intending to solve one environmental problem, an even greater problem will be created.
WHAT IS A SANDBANK
The Arklow Sandbank is similar to a sand dune system under the sea water. It is located approx. 6km to 18km off the Wicklow/Wexford coast. It runs parallel to the shoreline and extends some 27km from Wicklow head to Kilmichael Point at the south end and is up to 2.5km wide at some points. At some points it is over 40m in height over the seabed and is slightly covered by seawater at all times.
The Arklow sandbank have been formed over millennia by sand being carried up the east coast of Ireland, deposited in sandbanks and forming the beaches and sand dunes. The sandbanks form a buffer against tides, storms and rising seas. They also are central to replenishing the sand on our beaches along the south east coast. If wind turbines are erected on these sandbanks, we believe they will seriously interfere with this natural process and lead to the decimation of beaches and sand dunes.
WHY IS IT IMPORTANT
The sandbank runs parallel to the coast and forms a natural protection barrier to the scenic beaches and towns that are on the shore. It protects the coast from storms and Atlantic swells that can reach this part of the sea and the towns from flooding. The sand bank is already recognised as a conservation site under the EU Habitats directive (Annex 1) and should not be used as a site for industrial development.
The parallel coastline contains areas of designated Special Areas of Conservation which are beaches and sand dunes and the Wicklow Head SPA.These are areas of outstanding natural beauty and that are completely reliant on the continuing viability of the sandbank for their very existence.
NATURA 2000 SITES IMPACTED BY THIS DEVELOPMENT
| REF | Site Name | Distance of European site from closest point of the Proposed Development (km) |
|---|---|---|
| NPWS, 2017b | Buckroney Brittas Dunes and Fen SAC | 0.31 |
| NPWS, 2013a | Wicklow Reef SAC | 3.61 |
| NPWS, 2017a | Magherabeg Dunes SAC | 3.66 |
| NPWS, 2017c | Kilpatrick Sandhills SAC | 6.8 |
| NPWS, 2021a | The Murrough Wetlands SAC | 11.15 |
| NPWS, 4127 | Wicklow Head SPA | 9.0 |
LOCAL BEACHES THAT ARE PROTECTED BY THE SANDBANK ARE
All beaches along the parallel coastline are at significant increased risk of future erosion if this project goes ahead.
further Scientific Research is needed !
SECPA have been calling for independent Scientific Research to be carried out to establish that there will be no adverse effect on the coastal SAC & SPAs. The EIAR report and NIS provided by SSE contain a conclusion that there will be no adverse effect on the integrity of Natura 2000 sites. ABP should make their own complete, precise and definitive findings and conclusions and upon which they can determine that all reasonable scientific doubt has been removed as to the effects of the proposed development on the integrity of the relevant Natura 2000 sites
Wicklow Reef NPWS, 2013a in particular will be put in peril if this project is allowed to proceed. Construction disturbance and dredging will lead to sediment suspension and increased turbidity which will adversely affect marine organisms. This is the only known habitat in Ireland and the UK for the Honeycomb Worm. The effects of such large sediment movement driven by the tidal currents on the Wicklow Reef has not been adequately investigated
EXAMPLE OF DAMAGE – IMPACT ON BRITTAS BAY BEACH
The beach is already suffering from coastal erosion, but the south end of the beach has been suffering the most.
7 turbines were erected on the Arklow Sandbank in 2004 as a demonstrator project and significant erosion of the south end beach at Brittas Bay has been noticed following completion of these 7 turbines – We believe there is a direct connection between the erosion at the south end of the beach and the installation of the turbines.
Following the erection of the 7 turbines it was discovered that there was huge scouring of the sand at the bottom of the turbines. This was fixed by the installation of rock armour protection to secure the foundation of the turbines; this changed the sandbank and has deflected the tidal currents.
By 2016 there was such a build-up of sand at the base that it interfered with access of the support vessels to service the turbines. This has directly led to a Dumping at Sea Consent (S007-01) being granted to Arklow Energy Ltd on 1st March 2017 to move 100,00t of sand away from the Turbine Bases.
IF THIS IS THE EFFECT THAT 7 TURBINES HAVE HAD, IMAGINE THE IMPACT THAT 56 TURBINES & 2 OSPs WILL HAVE!
SECPA is in favour of wind energy as a renewable source but object to these proposed projects on the sandbanks and believe that, while intending to solve one environmental problem, an even greater problem will be created.
THE BIGGEST TURBINES IN THE WORLD ARE PLANNED FOR THE ARKLOW SANDBANK
The sheer scale of these turbines is frightening – extending up to 940ft these will be the same height of the Eiffel Tower. The closest one will be 6km off the shore.
The Developer’s EIAR statement shows that 190km of cables are to be installed. These cables have a limited tolerance for bend, so an almost flat surface around the base of the sandbank will be required to be formed. To do this, 986 acres of the seabed will be levelled and over 3.3 million m3 of sand excavated and dumped during construction. (Equivalent to 200,000 truckloads) This will be done by a cut and fill operation conducted in the most part by a dredger. Up to 2.6 million tonnes of imported rock /concrete armour (equivalent to 89,000 truckloads) will be required to secure the base of turbines and provide scour protection of the turbines and cables. The foundations will be secured with 95,860m3 of concrete grouting (equivalent to 14,000 truckloads)
There are no plans to remove the scour protection to turbines and cables on decommissioning, so what is installed now, will remain forever. This will have a major impact on the sandbank given that up to 59 fixed height locations, up to an acre each, will be introduced. We believe this will ruin the sandbank as it now stands.
They are too big and too close
Offshore wind farms are vast industrial complexes. Typically, they involve the following:
TOURISM
The south Wicklow/North Wexford area relies heavily on tourism which is driven by the natural beauty and the tranquillity of our coastal areas. The presence of such a large number of huge turbines will disrupt the pristine seascape, potentially deterring tourists who seek out the area for its natural charm.
The long-term economic impact on local businesses which depend on a thriving tourism industry cannot be overlooked. Brittas Bay beach is a primary tourist attraction of Wicklow. It is 5km long and has a Blue Flag status with lifeguards stationed during the summer months. This facility may be lost as a result of this development.
Is it worth taking the risk of placing 56 turbines on the sandbank so close to shore. This will certainly damage this “rich ecology” and seascape
DAMAGE TO SANDBANKS AND COAST
A wind farm should not be built on the sandbank which should instead be designated as marine protected area.
Construction/maintenance work etc on the turbines will cause untold damage to the sandbank, which has been a natural defence for the preservation of the beaches & sand dunes along the east coast for millennia.
The sandbanks should be designated as marine protected areas and consequently, should NOT have wind farms built on them.
HORIZON POLLUTION
A primary concern is the considerable visual intrusion that the turbines will impose on our scenic coastal views. The proposed steel structures, up to 287 metres tall, will dominate the horizon creating an industrial landscape that is starkly out of place in a natural coastal environment.
For perspective, the turbines will be higher than these well-known landmarks – The Castletimon Hill (the Old Man) is 236m, Tara hill is 252m. Bray Head is 241m & The Dublin Spire is 121m
The new project will dominate the unspoilt seascape seen from the coast and bear no comparison to the turbines already there – many people welcome the view with just the 7.
This will spoil the natural and unspoilt seascape of the east coast of Ireland and will have the potential for causing mental health issues.
In both the US and across Europe authorities are responding to concerns about the visual impact of offshore windfarms. An Bord Pleanála has recently refused permission on grounds of high value landscape & national landscape importance. Co. Cork, Ballybane Windfarms Ltd.
The sea is known for its therapeutic, psychologically restorative properties. People gravitate to the sea to look at it, walk by it, swim and boat in it and to live by it. It will be impossible to escape the negative visual imposition that the turbines will have on what is an otherwise structureless landscape. What is unspoilt will become spoilt.
This alteration will significantly diminish the visual appeal of our coastal area which is highly valued by both residents and visitors.
MARINE PROTECTED AREAS AND NATURA 2000 SITES
These sandbanks are natural formations and a recognised marine habitat. The Arklow Sandbank should be designated as a marine protected area along with the existing Marine SACs (Longbank & Blackwater sandbanks).
The Arlow sandbank should be declared a Marine Protected Area.
BIODIVERSITY
The Wicklow/Wexford coastline has many Special Areas of Conservation and Special Protection Areas which are protected under EU law and are now in danger.
Fixed bottom wind farms and the hard rock structures that they introduce are known to result in significant long-term reductions in phytoplankton content in surrounding waters. Phytoplankton are the base of the marine food change and consume carbon dioxide on a scale equivalent to forests and other land plants.
Suspended sediment can be transported long distances that may exceed 10 km from their source. There is a significant risk of destroying benthic ecosystems, starting from phytoplankton and the entire marine food web, which includes human seafood consumers. The Wicklow Reef SAC is in particular peril from this project and is located only 3.61 km away.
KITTIWAKES
Offshore wind farms pose a significant danger to Kittiwakes (a Red Listed species) because they fly up to 40km from land to feed. They are protected by EU Birds Directive . Wicklow Head is Special Protection Area (SPA) and is a breeding ground for Kittiwakes. These birds are experiencing a significant decline in Ireland. It is predicted that between an additional 170 and 190 kittiwakes will suffer fatalities every year as a result of collision with the Arklow Bank proposed turbines.
A loss of an additional 190 birds per annum would quickly result in a significant decline in population The project lasts for 36.5 years so that would be at a loss of 190 per year a total loss of 6,935 Kittiwakes over that period. It is unlikely that they would ever recover!
Red Throated Divers also nest on Wicklow Head and are a bird species under threat.
The Arklow sand banks is specifically noted as of ecological importance for birds with Arklow supporting 18,000 peak counts of feeding birds.
WHALES & DOLPHINS
Mammals such as porpoises, bottlenose dolphins, northern right whales, harbour seals and baleen whales can be disturbed by specific frequencies of underwater noise during construction, this noise is measurable at 120db as far as Cardigan bay Wales.
If this windfarm is allowed to proceed, as well as directly damaging subtidal reef habitats, it will be excluding birds, porpoises, dolphins, sharks and whales from rich feeding grounds, which will result in population decline.
Damage to the coastline and the eco systems
OUR CONCERNS
The sandbanks are a habitat for marine life and a feeding ground for birds and contribute to the natural supply of replacement sand for beaches and sand dunes.
The process of consenting to wind energy development on the foreshore to date, including Arklow Bank, has been developer-led and not plan-led. This approach is not in the public interest and may lead to sacrificing the existing Arklow Bank habitat, beaches, and sand dunes to the interests of a short-term gain.
The existing 7 turbines have already had an impact on the Arklow Bank.
Windfarms located so close to the shore, as proposed on the Arklow Bank and Codling Bank, are not environmentally acceptable and the certain damage to the coastline and the eco systems will not be forgiven by the Irish people in generations to come.
Use the slider to view before and after images for proposed new turbine plan
22km Wind turbine free zone off the South East coast
OUR PROPOSAL
Alternatives exist for this wind farm be located further out to sea and away from the Arklow sandbank on fixed bottom turbines in deeper waters of up to 70m deep or on floating platforms.
A 22km wind turbine free zone aligns with EU best-practices in order to protect biodiversity, our local fishing economy, our stunning seascapes and our tourism industry. We are in favour of offshore wind projects that do not negatively impact our communities.
This developer led proposal dating from the mid-1990s is outdated when only 2m water depths were considered to be possible. Modern engineering technology increases the depth of water that is possible and fixed bottom turbines can now be installed in depth of water up to 70m. Floating turbine technology is also available.
We believe that the solution is to move the Wind Farm away from the sandbanks and away from the coast and not located in the most fertile areas of the sea. This is technically and commercially possible and is in use elsewhere in the world.
It is a requirement of EU Directives that Alternative sites should be considered when applying for permission to build. In the case of ABWP2, no alternative sites were considered as this site is the subject of a Marine Area Consent (MAC). This site was previously determined by the Government and was established under the undemocratic Foreshore Act. This site has not been subject to the correct environmental scrutiny and procedures set out in EU Directives. These Directives have not been followed.
TURBINES POSITIONED 8KM FROM SHORE
TURBINES POSITIONED 23KM FROM SHORE
Wind Farms must be built on floating platforms further out to sea to protect the Wicklow and Wexford Coast that are already under serious threat because of Global Warming and Rising Sea levels.
An example of a successful campaign
The US is currently building offshore wind developments having reviewed their permitting system following widespread concern about the impact of the first US offshore wind farm (a 460MW project with 130 turbines), proposed by a private developer in Nantucket Sound in 2001. The proposal was rejected and the campaign to protect the Sound continues. See Alliance to Protect Nantucket Sound.
