This policy document has been developed as a position of the Fair Seas coalition but may not necessarily reflect the individual policy of each partner group.
Read or download the full PDF of Fair Seas Offshore Renewable Energy Policy Position
Fair Seas’ Offshore Renewable Energy (ORE) policy position has been developed collaboratively based on the current status and stated Government ambitions for marine renewable energy development in Ireland as well as consideration of relevant and associated policies.
This policy position reflects on six key issues pertaining to the development of offshore renewables in the Irish maritime area. This policy position is non-exhaustive, and will be periodically reviewed and changed if necessary to react to, and reflect, the emergence of new relevant National or EU policy, ecological information, or as more evidence becomes available on the environmental impact of ORE in Irish waters.
The policy position has been formed based on the ecological and environmental impacts of ORE only. While we appreciate that there may be other reasons upon which to respond to planning decisions or policy concerning marine renewable developments (e.g. visual impacts), we are a group of environmental organisations with a remit to communicate and advocate only on biodiversity and conservation matters.
There are a wide range of views and opinions in the environmental non-governmental organisation (NGO) sphere including the Fair Seas coalition, regarding the principles and practicalities of progressing ORE developments in Irish waters. However, this position paper demonstrates the breadth of agreement amongst the Fair Seas partners on many of the key environmental issues regarding the impact of ORE on the marine environment and Marine Protected Areas.
This policy position reflects on six key issues pertaining to the development of offshore renewables in the Irish maritime area.
1. The role of Offshore Renewable Energy in addressing climate change
Offshore Renewable Energy (ORE) technologies providing renewable energy generation are incredibly important in tackling the climate crisis, which itself is interlinked with, and can significantly worsen the biodiversity crisis. However, ORE must be progressed in the right way, in the right areas, and not at the expense of important habitats and wildlife. The fact that the climate and biodiversity emergencies are inextricably linked is a key consideration of our policy position.
2. National Marine Planning Framework and the Ecosystem-Based Approach
It is essential that ORE developments are appropriately located through the application of an Ecosystem-Based Approach (EBA) to Marine Spatial Planning (MSP). This approach puts environmental factors at the core of decision making, recognising that healthy and naturally functioning seas support the provision of important ecosystem services including carbon sequestration and storage, food provision, nutrient recycling, and space for biodiversity to live.
3. Marine Protected Areas and planning decision making
In line with an Ecosystem-Based Approach, the impact of ORE developments on the health and condition of Marine Protected Areas (MPAs) should be a key consideration in MSP and ORE site selection and suitability decision making. The MSP and MPA site selection processes should work in parallel to ensure MPAs are chosen and located where the environmental data and evidence demonstrate as being best for the desired conservation objectives of the site and network, as opposed to the absence of ORE development being an important deciding factor in decision making.
4. Offshore Renewable Energy infrastructure and compatibility with protected areas
Given the risk of ecological impacts to the marine environment from individual ORE developments as well as cumulatively from multiple simultaneous projects within a region, including to MPA qualifying interests, and that Ireland’s current MPA network is far from meeting its spatial quantity or effectiveness quality targets, Fair Seas believes a precautionary approach should be applied to the concept and application of MPA and ORE co-location. Furthermore, Fair Seas believe it is rational and proportionate to say MPA and ORE co-location should not be viewed as a default option, but rather only as a last resort in ORE siting decision-making and planning.
5. Other Effective Area-Based Conservation Measures
If ORE development areas bring about proven in-situ benefits to biodiversity and ecosystems (relative to before the construction of the ORE development), then they could be designated as ‘Other Effective area-based Conservation Measures’ (OECMs) as opposed to MPAs. OECMs by definition fail to meet the criteria of a MPA because they do not have conservation as their primary objective. Even though OECMs may in some instances assist individual nearby MPAs meet their conservation objectives, because they are not MPAs, they should not contribute towards national area-based MPA targets (i.e. the 30×30 target). Regular monitoring and reporting on the condition of OECMs is particularly important as it will help in ascertaining if the OECM is providing in-situ benefits to biodiversity. Pre-construction baseline monitoring is also a key consideration for this to happen effectively.
6. Precautionary Principle
All environmental decision making should be based on the best available evidence, but when good evidence is lacking, decisions to protect the environment should not be delayed, but taken using the precautionary principle and approach. If it is unclear whether or to what extent marine renewable developments will have an impact on the receiving environment or MPA, or whether alternative solutions or options will fully mitigate predicted impacts, the Precautionary Principle must be applied.
The impacts of human driven climate change are getting more severe; an Intergovernmental Panel on Climate Change (IPCC) report warned it is a ‘code red for humanity’. Meanwhile, human activity such as the overexploitation of marine resources, pollution, loss of habitat from new development, and climate change itself, are driving the continued loss and decline of biodiversity at an unprecedented scale both on land and in the sea. Scientists are also warning of the 6th mass extinction unless we radically change how we value and protect nature and the environment.
The climate and biodiversity crises are inextricably linked, meaning they can only be adequately addressed together, and can’t and shouldn’t be resolved at the expense of the other. This view is highlighted by the IPCC which recognises the ‘interdependence of climate, ecosystems and biodiversity, and human societies, and the importance of integrating knowledge more strongly across the natural, ecological, social and economic sciences’.
It is critical that policy and decision makers listen to and act upon the science on marine biodiversity loss in the same way climate science has become the foundation of climate change policy across the globe.
It is vital that Governments implement and deliver biodiversity commitments with as much attention, urgency and ambition as that of climate targets. There are many National, European Union (EU) and International level biodiversity targets and ambitions for the decades ahead. The EU’s 2030 Biodiversity Strategy is a plan for protecting nature and reversing degradation of ecosystems. It contains specific actions and commitments such as the establishment of a Nature Restoration Law, and enhancing the spatial coverage of protected sites to achieve 30% protection of land and sea by 2030. On the global stage, the recent Convention on Biological Diversity (CBD) COP15 Kunmzing-Montreal Global biodiversity framework of which Ireland is a signatory, committed to;
‘Ensure that by 2030 at least 30 percent of areas of degraded terrestrial, inland water, and coastal and marine ecosystems are under effective restoration, in order to enhance biodiversity and ecosystem functions and services, ecological integrity and connectivity’
as well as;
‘Ensure and enable that by 2030 at least 30 percent of terrestrial, inland water, and of coastal and marine areas, especially areas of particular importance for biodiversity and ecosystem functions and services, are effectively conserved and managed through ecologically representative, well-connected and equitably governed systems of protected areas and other effective area-based conservation measures, recognising indigenous and traditional territories, where applicable, and integrated into wider landscapes, seascapes and the ocean, while ensuring that any sustainable use, where appropriate in such areas, is fully consistent with conservation outcomes, recognising and respecting the rights of indigenous peoples and local communities, including over their traditional territories’.
Offshore Renewable Energy, especially offshore wind technology, is increasingly being looked upon to provide clean, low emissions sustainable energy. Many countries have set highly ambitious marine renewable targets, most notably in the UK which is aiming to produce 40GW of offshore wind energy by 20309. Whereas the EU’s ambition is to install 60GW of offshore wind energy by 2030 and 300GW by 2050.
Similarly, and in response to new sectoral ceiling emissions targets mandated by the Climate Action and Low Carbon Development (Amendment) Act 2021, Ireland has increased its 2030 offshore wind energy generation target of 5GW connected to the grid, with the addition of a further 2GW ‘to be in development’ by 2030. This Act also legally binds Ireland to a 51% reduction in emissions by the end of the decade.
It is well documented that ORE developments can impact negatively on biodiversity and environment (e.g. adverse effects impacting bird and marine mammal behaviour, physical loss of habitat, noise disturbance). Offshore Renewable Energy developments can also bring about potential biodiversity positives (e.g. artificial reef creation, enhanced source of foraging fish).
The scale of ORE development needed over the coming decade to meet the Government’s ORE targets is enormous. The Irish Government granted Maritime Area Consents (MAC) to ‘relevant’ offshore wind projects also referred to as ‘Phase 1’ projects, allowing them to proceed to the next stages of theplanning process16. In May 2023, Ireland published the results of the first Offshore Renewable Electricity Support Scheme (ORESS 1) auction in which four projects, with an energy generation capacity of 3GW, were awarded support through the scheme.
A large host of what were known as ‘Phase 2’ projects but which are now all incorporated into a State ‘Plan-led’ regime are also in the consenting pipeline, and together with the ‘relevant’ projects will help Ireland reach its 2030 targets. The expanding ORE industry is competing with an already busy spectrum of sea users and uses, including fishing activity, and areas designated for conservation. Ireland has committed to expanding its Marine Protected Area (MPA) network to 30% by 2030, but currently its spatial designation coverage in the
marine environment sits at only 9%.
Given the ever increasing impacts of climate change on the environment as well as society, the ongoing conflict in Ukraine and the Middle East, and the associated spike in the cost of fossil fuels, the pressure for EU Member States to become energy independent using clean and renewable sources has never been higher. It is essential Ireland continues on a path away from fossil fuel use for energy generation, and it is just as important we don’t exacerbate the biodiversity crisis with poor planning decisions resulting in the decline or irreplaceable loss of marine species and habitats. Restoration of degraded ecosystems and biodiversity is also an
important action to address the twin climate and biodiversity emergency.
Read or download the full PDF of Fair Seas Offshore Renewable Energy Policy Position
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