The memorandum of understanding between the UK and Irish Governments on the large scale production of renewable energy for the UK market illustrates the risks of decision making in the absence of strategic national spatial planning, the Irish Planning Institute has said in a submission to the Department of Communications, Energy and Natural Resources.

In its submission to the Department’s consultation on a “Renewable Energy Export Policy and Development Framework” emerging from the memorandum, the Institute acknowledges the economic and environmental potential of exporting renewable energy but argues that it must be part of a plan-led approach. According to the Institute the export Framework should not be prepared in isolation and requires the context of an overall national energy plan, supported by a reviewed National Spatial Strategy, which looks at all energy matters including grid infrastructure.

The Institute also argue that the Framework is premature pending the completion of a National Landscape Strategy. A National Landscape Strategy is required in response to Ireland’s ratification of the European Landscape Convention in 2002. While the consultation document refers to European habitat protection directives there is a real need to also refer to Landscape Character Assessment in the absence of a landscape strategy and to consider the cumulative impact of renewable energy developments, particularly on more sensitive landscapes.

According to the Institute there is no need to distinguish between energy projects for export or those for national needs as any large scale renewable energy project is likely to have the same spatial characteristics whether or not the produced energy will be exported. The Institute suggests that otherwise a distinction could equally be argued to apply to developments by foreign direct investment companies that produce primarily for the export market.