12 August 2021Liam CONNEALLYDirector of Economic DevelopmentPlanning Department, Clare County CouncilÁras Contae an Chláir, New RoadEnnis, Co. Clare, V95 DXP2Re. Observation on Planning Application 21757 by Art Data Centres Ltd. Tooreen, Cahernalough, Knockanean, Ballymacahill, Muckinish and Rosslevan, Tulla Road, Ennis, Co ClareDear Mr. Conneally,I write regarding the above application. I ask that you carefully assess this Planning Application against Ireland’s EU and Irish commitments to reducing greenhouse gas emissions. Should you be disposed to grant I request that Planning Conditions are put in place that will limit the development’s greenhouse gas emissions from the outset, and ensure they reduce over time. I note that an objective in the Clare County Development Plan (Objective 18.3) is “To promote County Clare as a Low Carbon County as a means of attracting inward investment to the County and Mid-West region”. A massive increase in the use of gas as an energy source would be incompatible with this objective. It appears that the use of on-site electricity generation from gas will be central to the energy supply for the proposed development. The use of fossil gas (natural gas) is not a low carbon fuel and would be at odds with this objective within the Clare County Development Plan. In this regard I note that UK regulators have issued a warning to Norwegian energy giant Equinor over advertisements on the London Underground that implied gas is a “low-carbon energy” source. The UK Advertising Standards Authority, ASA, told the Norwegian state-backed energy major not to use the advertisement again after a complaint was submitted about a poster seen in Westminster tube station. This is referred to in an article by Harry Dempsey in the Financial Times on the 15 September 2019. In short ‘natural’ gas is not a low-carbon fuel and other options must be considered as an energy source for the proposed development. Any new data centre should ensure that waste heat is used for district heating to maximise the benefits of co-location. This could be achieved by planning conditions. Given that the site is just four kilometres from Ennis town centre I ask that you ensure by way of planning condition that this will occur. While the applicant has stated that a vertical farm will be provided, this appears to more of a fig-leaf to mask the very high energy use of the facility. It would be much more appropriate, and I suspect more sustainable to provide heat to nearby homes in the town of Ennis. While I not that the applicant states that the available heat will not be at a high temperature, I suspect that it would be possible to deliver this heat as a valuable resource to nearby homes.The proposed development appears to be in breach of Ireland’s commitments under European Union’s Effort Sharing Decision. On Page 15 of the Applicant’s Environmental Impact Assessment Report (EIAR) states: “Data from the EPA in 2020 indicates that Ireland had total GHG emissions for 2018 of 60.93 million tonnes carbon dioxide equivalent (Mt CO2eq). This is 5.59 Mt higher than Ireland’s emission ceiling for 2018 as set under the EU’s Effort Sharing Decision (ESD), 406/2009/EC. Emissions are predicted to continue to exceed the targets in future years.” On page 16 of the EIAR it states that the proposed development’s emissions will be 657,000 tonnes CO2eq per annum. This is significant and needs to be carefully assessed against the targets identified in Ireland’s current, and forthcoming Climate Action Plans. I note that the six data storage facilities will require up to 200 MW load, and that it is proposed that this requirement will be provided by power from the national grid, and an energy centre with gas generators and emergency backup provided by diesel generators. While the applicant references green hydrogen as a future energy source, this might best be ensured by way of planning condition at the outset. The proposed use of large amounts of water for peak summer cooling must be carefully assessed. I note that the proposed development may require up to a million litres of water per day for cooling when temperatures exceed 27 degrees. This is likely to occur when water supplies in the Ennis are at their lowest and may cause supply difficulties for the town’s inhabitants. I have paid the required €20 fee by phone, and I request that you acknowledge this observation in writing. Sincerely, Ciarán CuffeCiarán CUFFEMember of the European Parliament A link to the original submission can be found here.