Wind Submissions Planning Section Department of the Environment, Community and Local Government Custom House Dublin 1

By email to: [email protected]

February 18th, 2014

Re: Proposed Revisions to Wind Energy Development Guidelines 2006 - Targeted Review in relation to Noise, Proximity and Shadow Flicker

Dear Sir/Madam,

This submission is made by Edward O’Grady, racehorse trainer, Killeens, Ballynonty, Thurles County Tipperary. Maria O’Grady, Ascendancy Ltd breeder. [insert name (organisation or person) and address]. [Party should state their interest in the Irish thoroughbred industry.]

I am writing in support of the joint submission made by Irish Thoroughbred Breeders’ Association, Association of Irish Racehorse Owners, Irish Jockeys Association and Irish Racehorse Trainers Association dated February 17th, 2014.

The Irish thoroughbred industry is under threat by a new generation of large scale industrial wind turbines which are an incompatible land use with the established thoroughbred industry in this country. Revisions to the 2006 Wind Energy Development Guidelines should not facilitate clear threats to the viability of the Irish thoroughbred industry.

(a) Targeted revisions to Wind Energy Guidelines should prevent the potential negative impact of wind farm proposals on the safety of thoroughbred horses and personnel, in particular ridden horses, because of the very real risk of thoroughbreds being adversely affected by turbines being located directly within their range of vision or hearing (noting thoroughbred horses’ highly evolved flight response and their particular sensitivity to perceived visual or auditory threats), and

(b) Targeted revisions to Wind Energy Guidelines should prevent the visible encroachment of wind turbine developments on the undisturbed rural landscape of stud farms and training yards which will result in a flight of capital from Irish studs and stables. It may also be a significant deterrent to future funding and support by overseas investors, who are integral to the industry.

Therefore,  thoroughbred breeding facilities, such as stud farms, stables, training yards and gallops, should be added to the Wind Energy Development Guidelines’ definition of ‘Noise Sensitive Property’, at Section 5.6.6 of the amended text to acknowledge the specific vulnerability of the industry to incompatible land uses such as wind farms,  Additionally, noise limits referenced in Section 5.6.8 should be amended to apply at the boundaries of these thoroughbred breeding facilities.  Separately, the definition of ‘other affected property (e.g. existing work places or schools)’ in Section 5.12.1, relating to Shadow Flicker, should be amended to include ‘thoroughbred breeding and training facilities’.

Yours sincerely,

Edward and Maria O’Grady

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