The Institute of Public Health in Ireland

Planning Policy Statement 18 Renewable Energy (PPS18)

We wish to make the following general observations in relation to the Proposed Plan: 

• IPH welcomes the sustainable approach by the Department of the Environment to encourage and facilitate the provision of renewal energy in Northern Ireland.
• PPS18 can support the move to reduce pollutants entering the environment. However there is a need to consider wider public health concerns in the adoption of PPS18. Encouraging renewable energy (while balancing this with environmental and conservation concerns) will benefit health locally, and on a global scale. Climate change has been identified as one of the most important public health challenges of the 21^st Century and therefore any policy which seeks to address this major issue is welcomed.
• Climate change is a major public health issue and PPS18 will assist Northern Ireland to meet targets set by the EU and the Northern Ireland Sustainable Development Strategy.
• IPH welcomes the development and encouragement towards renewable energy in Northern Ireland to support the collective effort to address climate change. Renewable energy can provide alternatives to traditional sources of energy which can contribute to reducing Northern Ireland’s carbon footprint. Northern Ireland’s current energy sources such as the burning of oil, coal and natural gas can result in a number of emissions (sulphur dioxide, nitrous oxides and other pollutants) which are deemed a risk to health[1]. The Health Protection Agency has developed the ‘Health Effects of Climate Change in the UK in 2008’[2] which clearly outlines the number of health impacts associated with climate change. These include floods, infectious and foodborne diseases and an increase in temperature change impacting on mortality levels. Any initiative to address climate change is to be welcomed.
• The household sector accounts for 26% of final energy consumption and 29% of carbon dioxide emissions. (Carbon dioxide is the main gas implicated in global warming).
• Low-income householders are more likely to be reliant on carbon-intensive fuels and inefficient heating systems, in particular a dependence on electricity-based heating. Also, these households generally lack the substantial finances necessary to retrofit their houses with more sustainable energy solutions. Similarly these households are likely to be excessively penalised by carbon taxes which can drive them further into poverty and social exclusion. Such households need to be careful consideration in developing and implementing PPS18.
• IPH supports the integration of renewable energy into all public sector development, large-scale urban development and dwellings in the countryside.
• Wind Energy

Wind Energy Development is one of the main sources of renewable energy in Northern Ireland and the health impacts of future developments need to be carefully considered especially the location of windfarms. Wind turbines can cause noise and visual annoyance and permission should take into consideration both location and design to minimise potential negative health impacts. Noise impacts include interference with sleep, annoyance, nuisance and dissatisfaction[3].   IPH calls for increased health considerations to be included in the Supplementary Guidance Consultation notes.

• MSW Incinerators

Emphasis should be placed on the need to reduce the amount of waste generated in Northern Ireland. Only then should the development of MSW incinerators be considered and it is essential that they are assessed for their potential health impacts prior to the establishment of any scheme or facility. 

• Integrated Renewable Energy and Passive Solar Design

All new buildings should be designed and developed to be zero carbon. In the current economic climate, Northern Ireland has a prime opportunity to promote and reinforce the inclusion of renewable technologies in all new buildings for both commercial and private uses.

All-island cooperation is welcomed given the similarities in the need to promote renewable energy in Ireland, North and South.   The Institute supports the collection of data, the conducting of research and development of guidance on an all-island basis to promote joint working and action in this area. The Institute as an all-island organisation has much experience in co-operation for improved health across the island and is willing to lend its expertise to further work in this area. 

• IPH calls for a Health Impact Assessment (HIA) to be routinely adopted for all new renewable energy developments. HIA takes into consideration the wider determinants of health and is a methodology which assesses the potential and unintended health impacts of an identified proposal. HIA uses both quantitative and qualitative methods to identify the health impacts on the population’s health and makes recommendations for decision-makers as to how negative health impacts can be mitigated and positive ones enhanced. HIA can also make a contribution to tackling health inequalities in that it specifically explores the impact of the proposal on sub-groups within the population. This will help to ensure that the Proposed Plan does not exacerbate existing health inequalities and that were possible steps can be taken to reduce health inequalities thus making a significant contribution to a more equitable society.

[1] DEFRA (2004) Review of Environmental and Health Effects of Waste Management DEFRA: London p16

2 Health Protective Agency (2008) Health Effects of Climate Change in the UK 2008, Department of Health.

3 Manwell, J.F. et al (2002) Wind Energy Explained, John Wiley & Sons, Chichester