Development plan · Limerick City and County Council
Limerick Development Plan 2022–2028 (as varied)
The council's development plan written statement: its strategy, policies, objectives and development standards.
Limerick City and County Council · 2022–2028 · 414 pages
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- Chapter 9: Climate Action, Flood Risk and Transition to Low Carbon Economy279 Objective CAF O23 Flood Relief Schemes It is an objective of the Council to support and facilitate the development of Flood Relief Schemes as identified in the CFRAM 10 Year Investment Programme and ensure development proposals do not impede or prevent the progression of these measures. Objective CAF O24 Minor Flood and Mitigation Works and Coastal Protection Schemes It is an objective of the Council to support and facilitate the Office of Public Works Minor Flood and Mitigation Works and Coastal Protection Schemes and ensure development proposals do not impede or prevent the progression of these measures. Objective CAF O25 Strategic Flood Risk Assessment It is an objective of the Council to have regard to the recommendations set out in the Strategic Flood Risk Assessment prepared to support the Plan. 9.3.1 Water Management Closely related to the idea of adaptation to flooding and management of water for flooding purposes is the wider idea of water management in a broader sense. Climate projections mention that summers are likely to be hotter and drier and this raises the possibility of drought, such as that in the summer of 2018. It is important that suitable allowance is made for climate change in flood risk responses. In this regard, consideration should also be given to water management in its wider context, not just in relation to flooding but also in relation to water storage and rain water harvesting to provide a reserve of water for possible drought periods. 9.4 Renewable Energy Renewable energy continues to play an important role in terms of energy production nationally and within Limerick. As technologies emerge and alter, Limerick needs to position itself, to ensure that it has a safe, secure, sustainable and affordable supply of energy, which is central in securing sustainable development. Renewable energy is defined as renewable non – fossil energy sources such as, but not limited to wind, solar, geothermal, wave, tidal, hydropower, bioenergy, landfill gas, sewerage treatment plant gas, bio gases and bio – char, in the EU Renewable Energy Directive. The Climate Action Plan 2021 includes targets to increase the capacity of renewable energy in Ireland. Ireland has a target of 80% of electricity sourced from renewables by 2030. The development of the updated Wind Energy Guidelines and the Renewable Electricity Development Plan will also facilitate informed decision making in relation to onshore renewable energy infrastructure. Local Authorities must also be consistent with the following national plans, policies and strategies when considering proposals for renewable energy: •• The National Renewable Energy Action Plan 2010; •• The Government’s Strategy for Renewable Energy 2012 – 2020; •• The Government’s White Paper on Energy Policy - Ireland’s Transition to a Low Carbon Energy Future 2015-2030; •• Interim Guidelines for Planning Authorities on Statutory Plans, Renewable Energy and Climate Change (July 2017); •• Wind Energy Development Guidelines, Planning Guidelines (2006), as amended or replaced; •• National Mitigation Plans (compliant with the Climate Action and Low Carbon Development Act, 2015).
- LIMERICK DEVELOPMENT PLAN 2022-2028280 From a renewable energy production perspective, Limerick has many attributes to support the development of renewable energy sources, sitting on the banks of the River Shannon, there is significant potential to harness the clean energy that could be generated, subject to an appropriate level of environmental and ecological assessment. The emerging concept of the Atlantic Green Digital Basin (GDB) can provide both a mechanism for achieving a green and digitally diversified region. The GDB can support a business cluster leveraging digital technologies powered 100% by our own generated green energy, becoming the centre point for Europe’s digital traffic and a global exporter of clean energy. The project identifies a number of key building blocks to enable the project to be realised and all will need to be considered in an environmentally sustainable manner. This includes the potential for the development of hydro and wind energy, utilising emerging ocean and wind technology, utilising the water to support economic development such as data centres and harnessing the knowledge and experience in the region in terms of bio economy. See Chapter 5: A Strong Economy for further details. The contribution of both large and small scale renewables, including domestic and agricultural is likely to grow, over the lifetime of the Plan. This has proven to be the case in many European countries, where micro renewables in the form of photo-voltaic installations on houses and other structures make a significant contribution to energy generation. Policy CAF P6 Renewable Energy It is a policy of the Council to support renewable energy commitments outlined in national and regional policy, by facilitating the development and exploitation of a range of renewable energy sources at suitable locations throughout Limerick, where such development does not have a negative impact on the surrounding environment landscape, biodiversity, water quality or local amenities, to ensure the long-term sustainable growth of Limerick. Policy CAF P7 Atlantic Green Digital Basin (GDB) It is a policy of the Council to support the development of Atlantic Green Digital Basin (GDB) proposals within Limerick and the wider region, subject to appropriate levels of environmental assessment and planning considerations and to work with relevant stakeholders to realise its potential. Policy CAF P8 Community Based Renewable Energy It is a policy of the Council to support the development of community based renewable energy projects, subject to appropriate levels of environmental assessment and planning considerations. Table 9.2 Renewable Energy allocations for differing technologies Output Current and Projected Wind Anaerobic Digestion Solar Hydro Geothermal Current capacity MW 234.35 2.0 113.49 0.1 MW 0 Target Capacity MW (2030) 386.45 (+65%) 20 (+1,000%) 227.0 (+100%) 0.3MW (+300%) 0.5MW Note: Baseline figures drawn from LCCC sources June 2020
- Chapter 9: Climate Action, Flood Risk and Transition to Low Carbon Economy281 Policy CAF P9 Renewable Energy Technologies It is a policy of the Council to consider all emerging renewable energy technologies, such as hydrogen electrolysis, pumped storage and smallscale anaerobic digestion and any other source of renewable energy technologies that are viable as a means of energy security, subject to the relevant level of necessary environmental and ecological assessments. 9.4.1 Bio-energy Production This aspect of renewable energy can lend itself well to collective community or district combined heat and power plants. Sources of bio-mass in Limerick can vary from products specifically grown for use as bio-mass fuels, such as Miscanthus or Short Rotation Coppice, to animal waste and by products of the food industry. The Council acknowledges the predominant nature of agriculture, within the rural area, including beef and dairy production and the importance of maintaining sustainable agriculture in line with the European Green Deal. Therefore, the opportunities associated with specifically grown products as sources of bio-mass may be limited. The forestry sector can also make a contribution to the bio-mass sector through the use of by-products from the forestry sector as fuel. Forestry thinnings and waste timber can be localised fuel sources. Objective CAF O26 Bio Energy It is an objective of the Council to support the development of bio energy and projects in suitable locations and subject to adequate assessment. The development of grid injection, where this is necessary for renewable energy input will also be supported. Technologies such as anaerobic digestion (AD) and dry digestion can play a role in helping to manage sources of farm waste in particular and can help to provide an outlet for farm waste, municipal solid waste, or by products from the food industry. Anaerobic digestion is the bacterial fermentation of organic waste in oxygen free conditions. The by-product of this is methane and liquid and solid residues, which are high in nutrient values, but are in a more easily handled form than the original wastes. This technology would be particularly appropriate for the treatment of farm wastes. 9.4.2 Hydro-power Traditionally hydro-power provided energy for mills and other enterprises in Limerick and depends on the harnessing of water power flowing from a higher to a lower level. It is usually only possible to exploit hydro-power resources where they occur. It involves the creation of a head pond and weir to provide sufficient depth to draw off water, a headrace –a pipe or channel to carry the water from source to the generation turbine contained within the turbine house and tail race to return the water to its natural course. Creating these structures will have an effect on the course of the river and may have ecological effects. While many of the locations that would have had mills in the past could be expected to provide suitable locations today, ecological and environmental concerns will have to be taken into account, such as fish passes to ensure that fish are not drawn into the turbine. This is of particular importance for salmonids, which during migration may be particularly vulnerable to this. Consultation with both the Fisheries Boards and the National Parks and Wildlife Service are required in order to ensure that fisheries and other ecological issues are taken into account. Many of the rivers and tributaries in Limerick are protected under the Birds and Habitats Directives and this should be a key consideration during the investigation of any development in or in close proximity to the watercourse. Objective CAF O27 Renewable Energy Production It is an objective of the Council to encourage and facilitate the production of energy from renewable sources, such as from bioenergy, solar, hydro, tidal, geothermal and wind energy, subject to appropriate levels of environmental assessment and planning considerations.
- LIMERICK DEVELOPMENT PLAN 2022-2028282 9.4.3 Solar Energy Solar energy has been an area which has seen significant development over the last decade. The basic principle is to harness and gain maximum benefit of solar energy, through the following means—passive solar, active solar heating and solar photovoltaic systems. There are a range of technologies available to exploit the benefits of the sun, including solar panels, solar farm and solar energy storage facilities, all of which contribute to a reduction in fossil energy demand. Limerick has experienced significant interest in the development of solar energy in the form of large scale photovoltaic solar farms, which is an emerging technology in Ireland, with a number of proposed largescale developments granted approval. Normal planning considerations, including impact on landscape, urban design, biodiversity, ecological impact, on-site water management, access to grid, security fencing, decommissioning issues and residential amenity, including potential glint and glare will require assessment. The Council encourages proposals in relation to solar PV in industrial/commercial settings, where installations can be sited at ground level or on rooftops. The Council encourages, as part of the design and planning process, an evaluation of the potential to incorporate solar PV (or other suitable micro renewable technology) into the design of all new developments, or extensions to existing development, or change of use proposals and to submit this evaluation with any planning application. Proposals in relation to hybrid installations of large-scale solar PV and wind will be assessed by the Council on a site-by-site basis taking into account ecological, scenic and other normal planning considerations. The Council will support utility scale solar PV development at suitable locations where it can be demonstrated that there are no significant adverse impacts. 9.4.4 Wind Energy The Council recognises the importance of onshore and offshore wind energy as a renewable energy source and its national energy targets. Improvements are required in the existing transmission network to fully harness the renewable energy potential in Limerick. The Plan supports maximising the potential of accessing new, emerging byproduct markets to advance the growth of Limerick and to assist in transition to a low carbon society. The Council recognises the significant contribution that wind energy can make as a clean sustainable solution to energy requirements and the role it can play in helping achieve national targets, in relation to fossil fuel reductions and consequently greenhouse gas emissions. The Council will continue to support and encourage the principle of wind energy development in accordance with Government policy and having regard to the Wind Energy Development Guidelines for Planning Authorities, or any update made thereto during the lifetime of the Plan, subject to the location and siting of such infrastructure and having regard to the extensive designations throughout Limerick in terms of Natura 2000 sites. Objective CAF O28 Assessment of Renewable Energy Projects It is an objective of the Council to encourage the development of wind energy, in accordance with Government policy and having regard to the principles and planning guidance set out in the Department of Housing, Planning and Local Government publications relating to Wind Energy Development and the DCCAE Code of Practice for Wind Energy Development in Ireland and any other relevant guidance, which may be issued in relation to sustainable energy provisions during the course of the Plan.
- Chapter 9: Climate Action, Flood Risk and Transition to Low Carbon Economy283 Map 9.1 Wind Energy Locations Wi LEG DATE: OSI LICENCE Ado Preferred Areas Areas Open for Consideration Areas Unsuitable Limerick County Boundary LEGEND DATE: DWG. No. CDP-C8-WED OSI LICENCE No. © Ordnance Survey Ireland. All rights reserved. Licence No. 2017/09/CCMA/Limerick City & County Council Adopted June '22 round treet Map Background © Open Street Map
- LIMERICK DEVELOPMENT PLAN 2022-2028284 In terms of wind generation, the Shannon Estuary has significant opportunities for off shore wind development, which presents potential for economic development in servicing these developments within Limerick. The offshore wind industry is projected to grow significantly over the next decade and offshore wind power is expected to account for a large portion of the Country’s energy demands in the future. Recognising the importance of offshore wind energy potential is a key consideration of the Plan. The necessary supporting infrastructure will be enabled on land, to facilitate connection to the network, subject to appropriate levels of environmental and ecological assessments. The port of Foynes is ideally placed to act as a support base for offshore wind, both during any initial exploration phase and also during the subsequent construction and operational and dismantling phases. Objective CAF O29 Wind Energy Development and Environmental Considerations It is an objective of the Council to facilitate the development of wind energy in an environmentally sustainable manner, ensuring proposals are consistent with the landscape character objectives of the Plan, the protection of the natural and built environment and the visual and residential amenities of the area. Objective CAF O30 Location of Wind Energy Developments It is an objective of the Council to promote the location of wind farms and wind energy infrastructure in the ‘preferred areas’ as outlined on Map 9.1, to prohibit such infrastructure in areas identified as ‘not open for consideration’ and to consider, subject to appropriate assessment, the location of wind generating infrastructure in areas ‘open for consideration’. Objective CAF O31 Wind Energy supporting Infrastructure It is an objective of the Council to support the development of appropriate landbased infrastructure and facilities at suitable locations, in order to facilitate the necessary connections for off- shore renewable energy projects. Objective CAF O32 OffShore Wind It is an objective of the Council to support: a) The development of offshore windfarm developments, subject to normal planning considerations, including in particular the impact on areas of environmental or landscape sensitivity. b) Terrestrial developments along the coastline to ensure adequate provision for connection to the national grid for offshore wind farms. Objective CAF O33 Development of Foynes Port It is an objective of the Council to support the development of Foynes Port, as a support base for offshore wind, both during any initial exploration phase and also during the subsequent construction and operational and dismantling phases, subject to appropriate levels of environmental and ecological assessments. Objective CAF O34 Wind Energy Development It is an objective of the Council to ensure that wind energy developments on sensitive or sloping sites, or any significant alterations to them, are accompanied by adequate assessment of the effects of the development on soil stability. Objective CAF O35 Community Based Energy Initiatives It is an objective of the Council to support community energy-based initiatives, subject to adequate assessment, to help achieve low carbon communities.
- Chapter 9: Climate Action, Flood Risk and Transition to Low Carbon Economy285 Objective CAF O36 Life Extension and Repowering of Wind Farms It is an objective of the Council to support the life-extension and repowering of existing wind farms, where considered appropriate and subject to an appropriate level of environmental and planning assessment. 9.4.5 Tidal and Wave Energy Tidal energy can provide reliable and predictable energy sources, due to the predictability of tidal events. The two main types of tidal energy extraction are tidal barrage systems and tidal stream flow turbines. Barrages are usually located across a tidal inlet and capture the energy of the tidal movement, by creating a barrier and channelling it through the turbines. Tidal stream flow turbines are located beneath the water surface and can be submerged so they are not seen or heard. Similar to wave devices, there are currently a broad and diverse range of technologies under development for harnessing tidal energy. The Shannon Estuary has the largest tidal range on the Irish coast and as a result has considerable potential as a tidal energy resource. The Strategic Integrated Framework Plan for the Shannon Estuary, prepared in 2012 has identified a number of sites with potential for tidal energy development along the Shannon Estuary. These sites have potential to be developed, with consequential benefits for the delivery of renewable energy. The ecological implications of the development of these sources of energy requires careful examination as they can pose a risk to marine life and fish passage. This is true of barrage type structures in particular. 9.4.6 Geothermal Energy The recent publication by the Geological Survey of Ireland of An Assessment of Geothermal Energy for District Heating in Ireland in late 2020, indicates the potential for geothermal energy in Ireland. Such energy is available at different depths, but to date in Ireland, it is only sources of shallow geothermal energy that have been exploited. Geothermal resources are categorised in terms of depth (‘shallow’ or ‘deep’) and/or temperature. A more precise way to categorise geothermal resources is by the enthalpy, or total heat content, that is available. Traditional volcanic geothermal systems have been termed high enthalpy and any other systems termed low enthalpy. One of the huge advantages of geothermal energy is that it can provide a consistent supply of energy, unlike wind or photovoltaic, which can be limited by weather conditions or daylight hours. Objective CAF O37 Geothermal Energy It is an objective of the Council to facilitate geothermal energy generating developments, both standalone and in conjunction with other renewable energy projects in suitable locations. Geothermal energy is usually captured using a heat pump. The heat pump operates in a similar fashion to a refrigerator, however the purpose of the heat pump is to harness large quantities of low-grade thermal energy (from water, air or soil) and boost the energy to deliver it at higher temperatures to a building heating system. It is suitable for both single and multiple buildings.
- LIMERICK DEVELOPMENT PLAN 2022-2028286 9.4.7 Emerging Technologies One of the technologies that has emerged over the last decade or so is air to water. Similar to geothermal, it works by extracting heat from air transferring it to liquid, which when heated can be pumped through a structure. This technology is often used as underfloor heating and for the provision of hot water. Further development of existing technologies, such as solar, more efficient geothermal and future development of marine energies are also likely to play a greater role during the lifetime of the Plan. The Council encourages the smallscale generation of heat and electricity by individuals, small businesses and communities to meet their own needs and as an alternative to, or to supplement, grid connected power. Exemptions set out in the Planning and Development Regulations 2001 (as amended) permit small scale generations for residential and commercial operations, subject to certain conditions. Objective CAF O38 Emerging Technologies It is an objective of the Council to facilitate and encourage future renewable energy technologies, such as hydrogen electrolysis, pumped storage and small-scale anaerobic digestion and any other source of renewable energy technologies, that are viable as a means of energy security, subject to compliance with all relevant planning criteria. 9.4.8 Carbon Capture and Storage The closest large scale carbon capture and storage project that has received funding from the EU is Ervia’s (Gas Networks Ireland parent company) Cork Carbon Use and Storage project, which will use the depleted Kinsale gas fields to store carbon. In a Limerick context, established means such as afforestation can play a role but should the opportunity arise to support or to use elements of carbon capture and storage in older infrastructural facilities, these options will be considered by the Council. Objective CAF O39 Carbon Capture It is an objective of the Council to support investment in initiatives to develop innovation, advances in technology and pilot projects for the sustainable development of energy storage and carbon capture within the region and to work with key stakeholders in developing sustainable forestry, including initiatives for native tree planting, conservation of peatland and better soil management, subject to suitable ecological assessment, to support carbon sequestration and enhancement of biodiversity. Objective CAF O40 Energy Storage It is an objective of the Council to promote the use of efficient energy storage systems and infrastructure that regulates energy supply and helps even out the variable nature of some renewable energy supply sources.
- Chapter 9: Climate Action, Flood Risk and Transition to Low Carbon Economy287 9.4.9 District Heating District Heating Network (DH) is a means of transporting heat as hot water through a network of highly insulated pipelines, delivering heat (rather than fuel) directly to buildings. This type of system can service multiple buildings on a local network with heat exchangers installed in each structure to distribute the heat internally. DH systems have been mainly powered by fossil fuels in the past, but renewable networks are now common throughout Europe. DH networks have the potential to decarbonise the heat sector where the heat demand is high enough. 9.4.10 Combined Heat and Power Combined Heat and Power (CHP) also known as ‘Co-generation’, is the simultaneous production of electricity and heat usually in the form of hot water or steam, from a primary fuel such as natural gas. Electricity is generated on site by driving an alternator connected to a turbine or engine. The heat from the combustion is harvested to provide steam or hot water that can be used on site. In a Limerick context, anaerobic digestion is perhaps one of the best examples where heat can be used on the farm, while electricity generated can be exported to the grid. It must also be recognised that natural gas, particularly renewable and indigenous gas, will continue to have a role to play in the transition to a low carbon economy. As such, renewable energy developments may require support from such sources in times of high energy demand. 9.4.11 Community Investment in Renewable Energy In recent years community supported renewable energy projects have had access to the energy market. There are many benefits to this approach towards renewable energy development, not least local control and local support for these projects. The Council will support such developments, as diversity of ownership and control of energy resources by local communities has a huge role to play in a just transition to low carbon economy. Objective CAF O41 Community Renewable Energy It is an objective of the Council to support and strengthen sustainable local/community renewable energy networks, micro renewable generation, climate smart countryside projects and connections from such initiatives to the grid. The potential for sustainable local/ community energy projects and microgeneration to both mitigate climate change and to provide for local fuel need is also supported.
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