Legal Obligations and Initial Designations
Failure to Protect Sandbanks under the Habitats Directive
When the Habitats Directive became law in Ireland in the late 1990s, Ireland had an obligation to designate a representative sample of our sandbanks within Special Areas of Conservation (SAC). These designations should have been based only on scientific grounds; socio-economic concerns were not to be entertained.
Despite a vast expanse of suitable habitat, there is not a single sandbank SAC north of Cahore Point in Gorey, County Wexford, due to pressure from the wind industry at the time.
A Developer-Led Project Under Minimal Scrutiny
Since 2002, we are first-hand witnesses of this political failure as the beaches and coastline of Wicklow and Wexford face man-made erosion because the Arklow Bank has been compromised from the nearshore wind development Arklow Bank Wind Park 1.
Over the years, sand has built up around the bases of these 7 small turbines, altering the height of this important headland-associated sandbank.
This developer-led project was given consent in advance of a final environmental impact assessment of the scheme, despite reports that highlighted the ‘unstable’ nature of the sandbank as a location for a wind park.
It was not subject to the precautionary principle to ensure that site conservation objectives were fully met, nor was it or alternative locations robustly reviewed as part of the Strategic Environmental Directive Assessment in 2010.
Technological Advances and Planning Failures
Outdated Projects in a New Era of Offshore Wind
This developer-led proposal dating from the mid-1990s is outdated when only 2m water depths were considered to be possible.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. SSE Renewables is significantly involved deep water fixed bottom turbine and floating offshore wind projects in Scotland and Japan.
In Europe the average distance to shore of offshore wind farms under construction in 2020 was 44 km.
However offshore renewable infrastructure is still infrastructure. It needs to be subject to best-practice meticulous planning and design, and requires rigorous evaluation using both environmental impacts assessments (EIA) and strategic environmental assessments (SEA). Unfortunately, over the past twenty there was no marine spatial planning or ecosystem-based site-selection process as set out by the EU and in the intervening years successive governments have failed to assess the environmental implications of full-scale development on the Arklow Bank itself as a sandbank and the iconic shoreline it supports.
So, in March 2022, the lucrative lease for the Arklow Bank Wind Park was increased from 520MW to 800MW as SSE Renewables, was awarded the new Marine Area of Consent (MAC) under the wholly inadequate Maritime Area Planning Act 2021.
With the act passed, allocation for offshore renewables supersedes the much-needed and long overdue designation of Marine Protected Areas (MPAs) and there will be no adequate interim measures to protect areas of the marine in the meantime.
This means that sites, including our most ecologically sensitive, may not be adequately designated and we could see offshore wind farms developed in completely unsuitable areas.
Ultimately this puts vital future energy infrastructure and the health of our seas and their ability to absorb greenhouse gas emissions at risk.
Offshore Wind Expansion vs Environmental Responsibility
Nevertheless, in June 2024, Sure Partners Ltd submitted an application to An Bord Pleanála to develop the remainder of Arklow Bank Wind Park with up to 56 supersized turbines, each almost 300ft tall with total capacity of 800 MW and two offshore substation platform on the Arklow Bank.
Research has shown that large sand banks protect the coastal areas from wave power stating that “removing, lowering or raising a headland-associated sandbank can have a significant impact on longshore sediment transport”. In other words, sandbanks play an important role in protecting the coast from weather extremes and in particular from coastal erosion.
In August 2025, following public consultation, An Bord Pleanála issued a comprehensive Request for Further Information (RFI) to the applicant – a hopeful sign of scrutiny. A response from Sure Partners Ltd (SSE Renewables) is in due in January 2026.
In a country where renewable energy projects already lie within MPAs or are at the stage of having an environmental impact the language of economics has been steering this ship. Offshore wind is pitched as an emerging market in Ireland with the potential to transform our national fortunes in tackling climate change.
“Wind is Ireland’s oil” – Taoiseach Micheál Martin
“Ireland is starting in the offshore renewables business with three advantages: a huge resource; a blank development sheet, apart from the 25MW wind farm off Arklow; and a positive working relationship between industry and policymakers. All of them need to stay focused on delivery without the distraction of a major change in development mode.” – Marine Renewables Industry Association (MRIA)
“We’re going to be supplying electricity, not just for Ireland, we will be exporting it into Europe. We are going to be a battery for Europe” – CEO of Wind Energy Ireland, Noel Cunniffe.
Instead, the environmental impacts of these projects should be robustly assessed for the full life cycle of the project, on a case-by-case basis according to the relevant nature conservation legislation, science-based and subject to the precautionary principle.
It is of no benefit to concede that a the plan-led ecosystem based approach is better than the developer-led approach and do nothing about it. The only policy that Ireland should be following is to not allow any renewable energy projects within MPAs.
