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Calls for ESB Executive resignations over decommissioning of Derrybrien Windfarm

With such wastage it’s time to make the ESB accountable for their handling of this.

Windfarm being decommissioned (Source Wind Europe)

On 16th March 2022, the ESB has confirmed that, after a refusal by An Bord Pleánala to get substitute consent planning, they will be decommissioning the windfarm at Derrybrien.   The impact of this has sent a shock wave across the ‘green planning’ sector and has left a lot of people outraged at the waste and their growing ESB Bills.   The South Galway Flood relief committee is asking for those accountable to be held responsible for this unmitigated disaster.

It should never have gotten to this!

Many people have expressed the opinion about can’t we just leave them up but that ship sailed a long time ago.  An Bord Pleanala rejected an application by the ESB for substitute consent, effectively removing any remaining avenue the ESB could use to avoid the Windfarm being tagged as an ‘Unauthorized development’. 

Since the first diggers tore into the mountain high-ground in 2003, it became an unauthorized development.  When the subsequent landslide happened in October that year, it should have been stopped.  They shouldn’t have dug tens of kilometres of new drains (some 2-3m wide and 2-3m deep) , again unauthorised.   The ESB refused, point-blank, to engage in any progressive way with local community concerns from Derrybrien Action group and the South Galway Flood Relief Committee. 

The extraordinary fines of €17,845,779 (as of this morning) , due to ESB’s delaying tactics, the loss of ESB generation for the lifetime of the Windfarm (est €50+ million), the environmental disaster, all rest 100% on the shoulders of the ESB Executive team.

If the ESB had engaged and addressed concerns, we wouldn’t be where we are today.

Decommissioning

Windfarms have a typical lifespan for 20 years but that can be extended by another few years. This would mean that the decommissioning would be happening anyway from 2025 onward. However the ESB in its substitute consent application indicated a timeframe of 2040, so may have had other things in mind including re-powering the windfarm. This means the ESB will incur significant losses of earnings by early decommissioning.

This judgement by an Bord Pleanala though harsh will save communities in the long run as it clarifies what can be at stake by taking shortcuts. This should be a wakeup call to any ‘Green Projects’ including Windfarms, forestry, Biogas plants and solar farms.

Paying the Price

I’ve stated before that there are no winners in this scenario- but,  I might be wrong here.  I have a suspicion that the ESB Executive team might be in fact the winners in this, while the rest of us are paying the price.

The South Galway communities have paid the price (and continue to pay the price) of the impact on the windfarm. In July last year the ESB put up notices effectively halting local turf cutting on the mountain due to peat instability – another slap in the face, without any notice/consultation.  

The lowering of water tables and extensive draining continues to increase the flood risk for South Galway.  It’s not just the communities that have paid the price, the environment has also paid a heavy price with the landslide destroying water life throughout the catchment and increasing the silting in the underground networks.

The Irish taxpayer (you and me) is also paying a price – We will be forking out close to €20 million in EU fines,  and the additionalcost of early decommissioning (~€10 million loss/year), consultants fees, resolution of Turbary rights, we could be talking about a total of taxpayer bill of well over €70 million.

When the EU slammed a court order on Ireland in 2012, the then ESB Boss, Padraig McManus,  took home  €700,000 in pay that year.  While wages were attempted to be capped , the ESB still has some of the highest paid execs in the public service, with massive bonuses.   So, I suspect that for the past 2-3 years , while the EU Fines have increased, the ESB executives have enjoyed substantially big bonuses.   In the meantime our ESB Bills have been rising and are now the highest in Europe. 

Therefore based on the continued impact on our communities, the significant cost to the taxpayer, the incredible damage to the ESB’s reputation, we are calling for the resignation of ESB Chief Executives, Paddy Hayes and Deputy Chief Executive Jerry O’ Sullivan.  

The ESB Executive team are fully accountable and must take responsibility here – they simply can’t remain the winners in this scenario.

David Murray, Chair, South Galway Flood Relief Committee

[I’d appreciate it if you could share. ]

References :

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Derrybrien Windfarm fines pass €15 million mark with no end in sight

Fines have passed the €15 million mark and a recent EC report finds a long-awaited ESB (remedial) environmental Impact assessment lacking. 

The ESB Is once again under the spotlight as the Derrybrien Windfarm resolution has been dealt another blow in the past week. As fines have passed the €15 million mark and a recent independent EC report has found that the long promised ESBs remedial environmental Impact assessment (rEIAR) lacking, and in some cases questions if the rEIAR is itself fit for purpose.

The report recommends that ‘further information is provided before the consenting authority (An Bord Pleanála) can make an informed decision’ . This could signal some more serious and costly delays in the resolution of this matter.

Quick Background/Timeline

  • 2003 : The Derrybrien wind farm was regarded as one of the largest in the EU when a landslide occurred during its construction in October 2003 by an ESB subsidiary, Hibernian Wind Power. 
  • In 2008, the EU’s Court of Justice criticised the State and ordered that the situation be addressed. It found Ireland had failed to properly assess the environmental effects the development would have on the locality.  But despite the ruling, no action was taken to rectify the situation.
  • In 2019, almost after 11 years, Ireland was €5 million for failing to carry out an EU court-ordered environmental impact assessment on a 70-turbine windfarm at Derrybrien, Co Galway with an additional €15,000 daily fine. 
  • In August 2020, after 11 years of stalemate, the ESB/Gort Windfarms  released a remedial )Environment Impact Assessment Report (rEIAR) (2640 Pages) and an Natura Impact Assessment (288 pages)

This report was assessed by local groups and individuals and in the past few weeks the European Commission release a report they commissioned from ARCADIS, consulting firm. The overall objective of the EC Technical assessment has been to assess if the ESB’s EIA remedial process has fairly assessed the key impacts over time and addressed appropriately the need for remediation and compensation measures.

Technical Assessment findings

The technical assessment conclusions state :

“Based on the technical review of the rEIAR against the requirements of the EIA Directive, it is recommended that further information is provided before the consenting authority can make an informed decision on this application. “

While the rEIAR is very comprehensive,  there are some key detractors.

  • It is not satisfied with the decommissioning aspects of the windfarm and in particular the management of all demolition waste is a major omission and renders the rEIAR non-compliant with the EIA Directive.
  • Although the rEIAR references the most up to date best practice guidance, a scoping process was not undertaken which is considered to be a very important best practice activity to ensure that the assessment addresses all the key issues with agreement from statutory consultees.  The lack of a scoping process is evident in the complaints from statutory consultees such as the South Galway Flood Relief Committee
  • The consideration of alternatives largely meets the requirements of the EIA Directive, its usefulness to decision makers is questionable and full consideration of reasonable alternatives during decommissioning has not been covered sufficiently.
  • There are inadequacies in the following key areas that invalidate the conclusions of some assessments:
    • Population and Human Health
    • Terrestrial Biodiversity
    • Landscape and Visual
    • Traffic and Transport
    • Soils, Land and Geology
    • Material Assets
    • Interaction of Impacts assessments.
  • The rEIAR excludes cumulative tree felling impacts stating that “only the impact of felling associated with the wind farm project was considered and any other felling carried out in the area during construction and following commissioning is beyond the study scope”. Given that the project involved the felling of 222ha of forest, this is considered to be a major omission from the assessment.
  • Given that construction is complete, decommissioning should be a key focus of the rEIAR, however, the conclusions that the assessments come to regarding adverse effects during and after decommissioning are not sufficiently evidenced.
  • The Soils, Land and Geology and the Major Hazards and Accidents chapters provide no evidence to demonstrate that the decommissioning phase would not increase the risk of a further peat slide.
  • The rEIAR adequately describes the emergency mitigation undertaken following the peat slide. However, the mitigation proposed during operation and decommissioning are in some cases inadequate and lack evidence to demonstrate their efficacy.

The EC assessment indicates that with the exception of the omission of an assessment of the likely significant effects of the project on the environment resulting from the disposal of waste, the rEIAR is generally in accordance with the requirements of the EIA Directive. However, inadequacies have been identified within the assessments which lead to uncertainty around the validity of the conclusions and the suitability and effectiveness of proposed mitigation.

Reaction and Analysis

This is playing like a broken record that every time it skips, the Irish taxpayer has to fork out another €5-10 million in fines. In a meeting in Brussels in February 2017, the EC asked the SGFRC to reach out to the Windfarm developer/operator (ESB) to highlight our concerns regarding increasing flooding and silting in South Galway.  We wrote the ESB a letter in April 2017, highlighting our concerns and attempted to engage in this remedial process.

The ESB stonewalled us and other South Galway stakeholders , essentially locking themselves in their ivory tower while they composed their rEIAR on ‘our’ potential impacts whilst ‘touting’  that had a robust public participation. There wasn’t a sliver of willingness  to engagement  – at this stage we think it’s a cultural thing in the ESB – it’s complete arrogance.

This lack of engagement was picked up by the EC Technical assessment.

The South Galway Flood Relief Committee submitted a complaint to the EC detailing how they attempted to contribute to the rEIAR but were ignored by the developer. The only communication they received in response to the letter sent to the developer in April 2017 was in a notice on 2 September (2020) stating that a rEIAR has been submitted to An Bord Pleanala.

Technical Assessment of Derrybrien Windfarm and Ancillary works

In our own analysis of the rEIAR, we highlighted some key items ‘missed’ in the EIAR that were submitted in 2017 letter. Notably the ESB thought that the nearest downstream flooding area from the windfarm was Gort (20km) and had no mention of Dereen and Beagh  (consider what happened to Hughie O’ Donnell’s house!)

And now unsurprisingly, the EC technical assessment has indicated that  ‘Considering the issues raised by the South Galway Flood Relief Committee, …some conclusions of the hydrology and hydrogeology assessment cannot be considered reasonable.  ‘

There was an opportunity to engage on this 3 years ago,  concerns had been outlined by the SGFRC, based on EC recommendations, but this was completely ignored by the ESB, so now the EC’s technical assessment is stating the obvious – The ESB needed to address community concerns!.

By ignoring that simple (and best-practice) rule, the ESB has just cost you, the Irish Taxpayer,  probably €10 million in fines.

Dammed If you do …

It would seem that An Board Pleanála have 2 choices now.  They can either grant consent but given the conclusions in this independent assessment, it’s highly unlikely that the EC will give this process the green light and remove the fine. We could then be back to square one in what could be a long drawn out process (years) on which a €15,000 daily fine is ticking so it could be tens of millions of Euro.

The other scenario is that An Board Pleanála refuses consent based on the observations of relevant stakeholders and the EC technical assessment and the process is restarted to create a more objective rEIAR.

Sometimes failing early is the better option and the ESB management must forgo their wounded pride and arrogance and do the right thing, the thing that they were asked to do many years ago – produce an objective and inclusive EIAR.

An Bord Pleanála are also not without scrutiny as within the chaos of this controversial development they overturned Galway County Councils planning permission refusal for some aspects of the Windfarm development.  However, by providing an independent technical assessment the EC has become a formidable chaperone of inappropriate ESB-An Bord Pleanála intimacies.

It will be interesting to see if An Bord Pleanála will have the objectivity that is required in this process but it’s hard to see how An Bord Pleanála can now grant consent after both local and EC technical assessments highlighted some major discrepancies in the rEIAR.

ESB senior Management need some pretty brutal scrutiny here for allowing this situation to deteriorate – trying to save themselves face as our significant cost. The public and our public representatives need to demand some accountability here -otherwise it’s the semi-state ESB tail that’s wagging the Governmental dog.

David Murray

Note : Please share if you can as you all are the agents of change!

References :

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South Galway flooding will get worse if nothing is done

If we leave things as they are South Galway flooding will get worse. A feasible solution has been found that will solve the worst of the flooding problems

Flooding in Blackrock – Photo Sean Brady

As part of a comprehensive 3 year analysis the unfolding scenario of South Galway flooding provides a grim outlook for South Galway. The worst flooding experience in 2015 is not the worst-case scenario- it get much worse. This article dives into the future flooding situation in South Galway and outlines light at the end of the tunnel.

In the analysis of a 1 in a 100 flood event, it is likely that South Galway will experience much more severe flooding than recent history. The M18 will flood. The N18 will flood. Gort will flood. There will be more homes flooding across the overall region. In 2015, 37 homes were flooded, in future scenarios, this rises to 50. The following scenario shows the potential flooding impact of a 1 in a 100 year flood.

The worst affected areas are Blsckrock\/Skehanna, Gort Town and Cahermore. In an extreme flood event 50 homes will flood and a further 23 would be at high risk which is <75cm to floor level.

Buildings flooded

In addition to homes flooding, there could also be 65 Non-residential properties flooding which include 20 slatted sheds/farmyards, Garages, Thoor Ballylee, Kiltartan Church and Graveyard, businesses in Gort (8)

Communities Isolated

As we have already experienced, there could be even more significant isolation within South Galway with communities like Rinrush cut off completely for over 3 months. Overall it is estimated that 175 homes and 75 non-residential properties would be cutoff. The M18 motorway would be in flood, the N18 would also be flooded so if you wanted to get from Galway to Gort, the only option would be to go via Loughrea.

The whole of South Galway would be paralyzed and common day tasks like getting kids to school, shopping, going to work, delivering feed to cattle, would be an arduous task ,not just for 1 day or so, but potentially, for months !

Many in South Galway already know this situation. In some cases a 500m, 1 minute drive to Kiltartan School was turned into the a 50km 50 minute round-trip to Loughrea. I’ve heard similar experiences with some young mothers in Cahermore clocking an additional 700km a week just to bring and collect their children from school.

In the past, some farmers had to relocate their cattle from their sheds to friends, neighbours sheds or even into Gort Mart. So, a 10 minute feeding time twice a day can become a two hour task, traveling several kilometers.

In future flooding scenarios, 49 individual sections of road would be flooded, including Crowe Street, Gort. The Kiltartan to Kinvara connection could be flooded for 99 days.

This level of isolation has a major impact on the life and soul of a community and businesses would see a catastrophic impact in the region.

This is the future reality of South Galway flooding, with Climate Chane considerations, and our committees remember the pain very well – be it a long-stay in a local hotel room for weeks, sleepless nights with the drone of pumps in the background, the alarm clock set an hour earlier to get kids ready for school, the anxiety of farmers as their livelihoods are under threat consistently for months.

Dynamics of flooding

The forensic analysis of flooding dynamics rely on statistical analysis on each of the floodplains as the complexities of the overall South Galway region arealmost impossible to gauge – its possible that the Blackrock/Skehanna flooding scenario could happen one year and Gort is OK, only to be reversed on the next flood event. In summary.

The frequent flooding scenarios that we’ve experienced in the past 3 decades will continue and get worse.

Light at the end of the Tunnel

So, yes, that was the grim reality of what South Galway will probably experience frequently in the future if things were to remain the same.

Public Consultation

Over the next 4-5 weeks, there is a public consultation on an emerging preferred scheme and we would recommend that people engage with Ryan Hanley consultants to understand the current flooding impact and the proposed solutions to alleviate extreme flooding. All information can be found here.

The details are as follows:

Recommendations are to leave feedback or contact the project team to answer any questions you have.

Summary

The outlook of flooding in South Galway looks bleak but the proposed scheme could address this. We recommend South Galway residents, business owners, farmers to give their feedback (positive, negative, or any concerns) on the scheme as part of the public consultation process.


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South Galway on the verge of Spring Flooding

In October last year, high winter water levels and flood relief delays was leaving South Galway exposed to flood risk.   While August and September 2019 were close to double the expected rainfall, October and November had less rainfall than normal and it looked positive that the South Galway would escape yet another winter without flooding.   Some people had expressed this to me that we were coming out the far side of this and it was unlikely that we would get flooding now. Some people were more cautious reflecting back to 2014 when we had a significant spike in February 2014.

img_2820
Blackrock Turlough, Peterswell had almost disappeared 2 weeks ago

Less than 2 weeks ago,The Blackrock Turlough, Peterwell,  was close to disappearing and this morning it’s less than 1m from the road between Peterswell and Skehanna. There is more to come off the mountain and there is more rain on the way.

 

south-galway floods

While recent rain it not the dramatic rain downpours of 2009 and 2015, or the large flooding volumes either, its a slower creeping buildup of water levels.  This latest rainfall will likely flood roads around Tierneevin (just flooded across road as I’m typing..) and Tarmon and potentially by the weekend some roads around Blackrock, Peterswell, Ballylee, and we still have unpredictable weather over the next few weeks.

We have in some ways been lucky in the past 2 weeks.  While Storm Ciara packed a quick punch of rainfall, Storm Dennis hopped off us and landed with a vengeance in England where it offloaded a months rain in 48 hours.

However, even today Thursday 20th of Feb, the outlook is for Heavy rain tomorrow and Monday.

rainfall

The following graph shows the water levels at Russaun, the outlet of Lough Cutra. This essentially is the level of water that flows through Gort town (and eventually into Kiltartan)

south-galway floods2

Up until 9th February, the levels had stabilized and then Storm Ciara hit which surged levels. Storm Dennis and yesterdays rainfall have kept the levels up.  This level of water won’t cause any sudden flash flooding but will continue to fill up Coole, Caherglassaun and Cahermore and make South Galway more susceptible to severe flooding if we get a further ‘winter’ storm.

The key concern here is that if we got another severe storm, then we could see a similar surge as we did with Storm Ciara on top of current levels  – which would likely bring several flooding to the area.

On the backdrop of this, Galway County Council is due to submit Feasibility report in the coming weeks (Last date given was Q1-2020)  – which will then decide on the future and viability the South Galway Flood Relief Proposal.  South Galway, now, more than ever needs solutions not more failed report or expensive studies.

We are at the ‘right’ side of the flooding season and hopefully we will make it through unscathed.  We are coming very close to the time to call out our elected representatives on their commitments to finally eliminate flooding in South Galway.

We should be keeping in mind a storm of a different kind if this much needed project fails to make it through.

David Murray

 

 

 

 

 

 

 

 

 

 

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Derrybrien Windfarm debacle could now cost us well over €4 million and rising

If this penalty application gets through in December – the Irish Government will have to pay over €4,168,000 into the ‘European Union own resources’ account and then continue to pay €10,000 per day thereafter.

From a previous article, Derrybrien Windfarm – Government and ESB treating us like fools,  we highlighted that the Irish Government was treating us like fool as European fines were mounting up on a daily basis – The situation looks a lot worse!

Here is the story so far: (In short)

  • In 2003, The Derrybrien Windfarm Developers (ESB – 95% owned by Irish Government)  didn’t do a proper Environment Impact Analysis for their development and proceeded with development and caused a massive landslide
  • In 2008 : After analysis the European Courts ruled against Ireland with a court order to reassess the Environmental Impacts and put in proper mitigation in place.
  • In 2008, the Irish authorities informed the Commission that the wind farm operator  (ESB) had agreed to provide an updated environmental impact assessment
  • In Jan 2018, the Court of Justice of the European Union (CJEU) issued a statement which indicated that Ireland would face fines of over €2m.  The court stated that even at this late stage, a full EIA must be conducted, which must include full consultation with residents, industry and other relevant stakeholders.
  • In April 2019, a That leads up to last Monday when the CJEU met in Luxembourg on the case. The full contingent of Judges (15) were there to listen to Ireland’s progress since January last year – it wasn’t great and the Irish Government was harshly critizied as it had not acted to implement the earlier judgment and there was quite some disbelief that Ireland could/would not act more decisively against a 95% state owned company. (ESB)
  • On 13 June 2019 an Application for an order to pay a penalty payment and a lump sum)  was proposed by the Advocate General to the Court and the picture is a lot starker.

Irish Government Response (or lack thereof)

Before we dive into the money – an interesting point to consider is that Richard Bruton Minister for Communications, Climate Action and Environment is also responsible the the ESB (well 95% responsible anyway) and obviously responsible for the Environment – so – this should have been easy as the buck stopped there.  After the April 2019 Judgement, frustrated by Government in-action I compiled a set of questions that I wanted the get answers to:

  • What progress has been made over the past 11 year and specifically, what actual progress has made in the past year, since the EU indicated potential fines of €2Million and 12K/day thereafter?  
  • Why does Ireland seem unprepared and unprofessional in this. (To quote an EU environment enforcement officer ” There was quite some disbelief that IE could/would not act more decisively against a 95% state owned company. ” What is causing this delay?
  • As its likely that we will now receive harsh fines – Who will be footing this bill? Will this be the ESB or the Irish Government?
  • What are the Governments plans to rectify this and when will this happen?

In order to get clarity I asked our local Fianna Fail TD, Deputy Anne Rabbitte to help get some clarification here and I asked her to frame some Parliamentary questions about this to the Minister for Communications, Climate Action and Environment.  This she did and this was the response from the Ceann Comhairle 

“I regret to inform you that I have to disallow the (questions) … The Minister has no official responsibilities to Dail Eireann for this matter and is a matter for the ESB which is independent in its functions.”

parlimentaryQuestions

We are not allowed to ask questions about a potential large penalty to be imposed on the Irish Government by the European Court of Justice on an environmental infringement.  We are told we have to leave it to the ESB, a company 95% owned by the Irish Government, who promised to carry out an Environmental Impact assessment over 11 years ago because it is independent in its functions.

I can see how the European Court of Justice as critical of Irish Government governance = tail wagging dog

 

 

Potential Penalties

This is only an application and the final judgement will be given in a few months time, likely be the end of the year.  This application has proposed

  • A lump-sum fine calculated at a rate of €1000/day from the date of the Court Order to the date of final judgement
  • A daily penalty of €10,000/day from the date of final judgement until the matter is fully resolved.

This isn’t news (we have always known) that this was coming down the road – ESB could have avoided this – The Irish Government could have avoided this by just doing the EIA.

If we say the final judgement will be 1st December 2019. That’s exactly 4168 days since the Court Order. (3rd July 2008)

If this penalty application gets through in December – the Irish Government will have to pay over €4,168,000 into the ‘European Union own resources’ account and then continue to pay €10,000 per day thereafter.

Note :  This amount is 3 times the normal amount we should be paying because of the lack of response – Ireland got the maximum multiplier factor of 3 for this.

How does this relate to flooding in South Galway?

The original EIA of the wind-farm indicated that there would be no additional drainage on the 4sq KM site on the main Slieve Aughty Peak.  After the landslide happened the developers put in place a ‘Robust-Drainage‘ Scheme, which involved digging 6ft x 8ft drains from each of the 71 turbine bases .  Overall, the drainage of the site was impacted by:

  • 200 Hectares of forest was clear-felled
  • Over 30 km+ of drains were dug
  • Over 17km of roads were constructed
  • 71 turbine bases were dug out and  constructed

With no impact assessment – how knows the effect the wind-farm has on the drainage but if you now consider this picture you can see why Derrybrien, Gort and South Galway communities should be concerned.

derrybrien_rivers_gort.JPG

The severe flooding in Gort in 2009 was from the Gort River which comes down from this area.

The South Galway Flood Relief Committee want the same thing as Europe here – a proper assessment on the impacts of mountain operations in this area and retrospective mitigation to ensure that potential flooding impacts from the wind-farm are mitigated in some way.

The real frustration here is that rather than than investing in flood mitigation ware are throwing away money having to pay these penalties because organizations that could be contributing to the flooding won’t do the proper assessments and the Irish Government is standing idly by as money pours down the drain  – Meanwhile the South Galway Flood Relief project has a risk of not progressing because it could be deemed to be too costly

This is something that we need to get vocal about as this is our money we are wasting and our flooding solution that could be in crisis.  Please share!

Thanks,

-David Murray

 

 

For more information on the Derrybrien Windfarm Saga :

 

Notes:

  • There are other groups in South Galway are affected by the Windfarm landslide also. This has not been touch up under the South Galway Floods Blog.

 

Flooding scheme design racks up 2.7 million in costs

In January 2017, Galway County Council appointed a project engineer for the South Galway – Gort Lowlands Flood Relief scheme and the first item on the table was to develop a brief for the scope of works for project and issue tenders for consultation work. The brief took 7 months to develop the 127 page Project Brief which outlined the scope and key objectives of the flood relief scheme project. In September 2017, tenders were requested for design engineering and environmental engineering of the project and subsequently Ryan Hanley were appointed the design consultants, with Mott McDonald being appointed environmental consultants. Trinity College/GSI became consulting partners as they developed hydrology models for the scheme to

Its took 3 years to publish the feasibility study which included the development of the hydrology model, the full flood risk assessment of the South Galway catchments and the high-level scheme design and initial cost-benefit analysis and environmental criteria. Against a background of failure to progress a feasible solution was found (see Against all odds – A Feasible Flood Relief Solution found for South Galway) . This was a first for South Galway as a previous flooding report by Jennings’ and O Donovan deemed a £40 million (€50 million) project infeasible – it cost £1 million (€1.26 million) to produce the report and sparked extreme reaction in South Galway Communities.

Headline from Connacht Tribune May 29th 1998

Since the publication of the new feasibility study in October 2020, a detailed design and environmental consultation has be undertaken. This has included a detailed geological analysis of about 16km of channels and environmental impact analysis for salinity on Galway Bay.

Racking up the costs

Between the project engineer’s wage, design, engineering and modelling consultants and various surveys etc, the project has racked up €2.7 million in report development and there’s still 4-6 months to go including public consultation and finalizing the solution so this will be expected to be over the €3 million figure.

Go or No Go!

This project has 2 key criteria to pass in the next 2 months.

  • A positive final Cost-Benefit Result
  • A feasible environmental solution

Given the rise in inflation in the past year, the project costs are now expected to rise significantly to somewhere between €20-€30 million. There is now a new review of project ‘benefit’ or how much the flood relief solution would save and hopefully this will also have inflation factored in.

Given the €1.26 million already wasted on a defunct report in 1998, it would be a diabolical waste for an extra €3 million to be added to this if the project fell short a few million. We need strong commitment in order to push through this solution to ensure the people of South Galway don’t have to feel the threat of serious flooding every winter .

A failure due to cost-benefit should not be allowed to happen. We’ve spent enough on report after report wasting valuable money. We need strong representation from our elected public representatives from out County Councillors and also our TDs/Ministers so we will be calling on Minister Anne Rabbitte, and deputies Ciaran Cannon and Sean Canney to deliver on the promises they made in the 2016 elections.

We also need your support to ensure that this solution goes through and all the great work done to get us this far is not relegated to gather dust in some far off corner of Galway County Council offices.

Please Share if you can

David Murray,

Chair, South Galway Flood Relief Committee

Windfarms and flooding – Resistance is Futile

Recently the Connacht tribune reported that EU fines on Derrybrien wind farm will finally come to an end on foot of formal plans that the plant is going to be decommissioned. Once an Bord Pleanla refused ‘retention’ for the controversial windfarm, by law it became an unauthorised development and by law it would have to be removed – no special treatment – there was only one way it would end.

This didn’t stop of course a stream of politician’s trying to grab headlines and turning the tide, reopen – it was cringe-worthy to see the procession of windfarm tourists, coming out on day trips, stamping the ground and declaring that all was well (See Swimming pools, turkeys and Windfarms)

The Connacht tribune in a recent article on 9th Feb however, incorrectly reported that the South Galway Flood Relief Committee ‘resisted‘ a last ditch attempt to reopen the farm. That isn’t accurate because the South Galway Flood relief Committee doesn’t have mandate on what happens to windfarms but we do have a mandate to reduce flood risk in South Galway. Our concern was over the political debate and that existing flooding issues were being downplayed due to the populist political narratives (see Contentious calls for windfarm reopening. We were being realist, not populist. Resistance against our planning laws was futile and since the planning refusal the windfarm became a dead duck – this didn’t stop it becoming a political point-scoring issue.

There is almost €20 million thrown down the drain in fines and still South Galway remains vulnerable to flooding. We’ll be waiting for final South Galway flood scheme designs and cost-benefit conclusion in the coming months and we will be keeping a very close eye on this.

We need our local public representatives to focus on this vital issue for South Galway, now more than ever -no distractions over the coming months!

South Galway Floods Update – Dec 2022

This November issued a stark reminder of how vulnerable South Galway is to flooding. Significant rainfall filled up the rivers and turloughs in the region and many people in the community were feeling the worry over a long wet winter and possible flooding again. The last substantially damaging floods were in winter 2015 which is 7 years ago. The is the largest gap between major flooding events and in that time frame people begin to wonder – will it ever happen again. The answer is a definite ‘yes’ and it will get worse – if nothing is done.

Luckily we have a South Galway Flood relief Scheme that was kick-started in 2017 that continues to progress through the key stages but a lot more slowly than anticipated. We are now at the phase of the project where there’s lots of work ongoing but not a lot in the public eye.

The feasibility study published in 2021 brought us an emerging preferred scheme – rough sizes and routes of channels to balance the water network across the catchment and a positive Cost-Benefit for the scheme.

The current phase we are in involves detailed design of each and every channel and full geophysical analysis of soil, environment and detailed discussions with landowners etc. Using this level of detail, the environmental impacts can be analyzed and assessed and this is the bulk of the work. Here is a summary of whats going on currently.

Design/Engineering:

  • Ground Investigation works are almost finished (with investigations at Kiltartan and Caherglassaun conduits completing shortly. Interim reports have been provided on an ongoing basis with final report completed over the next month
  • Culvert design progressing on N67. To be submitted to local National Roads Project Office when completed, for assessment and advancement
  • Awaiting production of habitat mapping to determine if weirs required on scheme
  • Drop-tests progressing on some swallow holes
  • Site meeting held with Clare County Council in November. All recommendations in the Ryan Hanley Road raising report were reviewed. Some works have already been completed. Critical works for Clare Co. Co. were highlighted
  • Detailed design proposals have been submitted to Irish Rail to allow them commence their design and funding procedures
  • M18 Culvert proposals – proposals are being progressed
  • Draft plans and sections for the scheme have been completed. To be finalised following final environmental inputs.

Environmental:

A significant amount of environmental surveys have completed and additional ones have habitat,

  • Targeted botanical surveys finished in October
  • Baseline noise surveys completed
  • Agronomist has completed site visits and feedback to project team
  • An additional Winter Bird survey has commenced and will continue until March 2023
  • Habitat mapping for all turlough areas of the scheme is due to be completed this month.

Timeline

  • March 2023 : Revised Cost-Benefit Analysis
  • April 2023 : Options assessment Report Completed
  • July 2023 : Environmental Impact Assessment completed
  • July 2023 : Public Exhibition of proposed scheme.

Following feedback from the public exhibition, the scheme design/reports will need to be refined and the report will then be sent to the Minister for OPW for approval and it is hoped that construction can begin in 2024.

One thin that we need to keep an eye on will be the Cost-Benefit Revision. While the project team will be assessing the project costs and potentially taking inflation into account, we want to see the ‘benefit’ treated in the same manner for a fair assessment.

Summary

There has been a huge activity in getting the mandated level of detail for a scheme this size to get to the right design detail and environmental reports. It is a substantial body of work and reports are going to be delivered from March to July 2023.

We look forward to a positive outcome that will set us up for the delivery of a scheme to end the threat of flooding for many in South Galway.

We wish you a happy Christmas and new year!

David Murray, on behalf of the South Galway Flood Relief Committee

South Galway Flooding Update : Sept 2022

While it’s appeared quieter on the flood relief solution front over the past few months there’s has been a lot of work on going in the background. With feasibility and public consultation completed, this phase of the project is about taking public consultation feedback and refining the details to a preferred scheme. It is now all about the detail.

  • Refined scheme development
  • Field/Impact Assessments
  • Produce Environmental Impact Assessment Report
  • Final Cost-Benefit analysis
  • Produce and run Public Consultation

Scheme Refinement

The Scheme development and refinement is about getting to the next level of detail. The last public consultation drew up indicative routes of channels and flood works – broad-stroke lines on maps and these were presented during the public consultation phase and discussed on many site visits. This (and other inputs e.g. environmental) informed the scheme development and the next phase of development was undertaken to bring more detail to the scheme.

This results in very detailed drawings showing the works, depths, heights, widths of channels etc.

Because this is also a construction project, there are even more details to consider e.g. machinery access, storage, earthworks storage etc.

This obviously constitutes a huge scope of work and there’s a lot of information sharing required with landowners. The project has also appointed an agronomist, John Bligh, who is liaising directly with landowners and walking through details of proposals and making note of feedback.

Environmental Impact Assessment Report (EIAR)

A key input to the EIAR are field assessments – basically going out on the ground and looking at many environmental factors, biodiversity, Noise, landscape, visual impacts, hydrology, Archaeology, salinity modelling etc.

These assessments then inform the actual EIAR, which again will be a substantial body of work.

Final Cost-Benefit Report

Soil and Geology investigations with detailed design drawings can inform the scope of works and final project costs enabling a final Cost-Benefit report to be completed.

Public Consultation

When all the above has been finalized, these will be submitted for final public consultation for several weeks . This consultation will be in a physical venue area rather than online meetings like the previous one.

Timeline

The following is the expected timeline with a goal for this phase to complete in April/May 2023.

TaskDescriptionCurrent Target (Aug 2022)
Consider Design Changes following GI ConsiderationsGI ReportGround Water Monitoring  Q3 2022
Field AssessmentsSoils, Geology, Hydrogeology Noise and Vibration Landscape & Visual Archaeology, Architectural and Cultural Heritage Biodiversity Salinity ModellingQ3 2022 Ongoing and will continue to Q3, includes for additional assessments that have been identified)
Scheme DevelopmentRefine Emerging Preferred Scheme (post Environmental Baseline Surveys) Additional TCD Model Runs in parallel with scheme development Construction Methodologies Plan and Section Drawings Quantities and Cost Estimates- Updates to above following Scheme UpdatesQ3 2022
Final Cost Benefit Analysis Report – Q4 2022
Environmental Assessment –Provide Engineering Info for EIAR/NIS
 Valuation Survey Aiming for Q1 2023
Exhibition Documents Aiming for Q1 2023
Public Exhibition Q1 / Q2 2023  

Summary

We acknowledge that this process is slower than expected but the project is progressing in the right direction. We are getting a glimpse of the level of details that are required to implement this scheme. The project agronomist, John Bligh, is continuing his visits to landowners over the coming weeks and feedback from many landowners is surprise of the level of detailed information that is now being provided.

There may be further updates in the coming weeks and if we we’ll keep you posted!

-David Murray, on behalf of South Galway Flood Relief Committee (SGFRC)

ESB Derrybrien windfarm application refused

An Bord Pleanala has refused the application for ‘substitute content’ by the ESB for the development of the Derrybrien Windfarm. Substitute consent seeks retrospective planning permission for a project that is not compliant with EU law and is granted by the planning board in “exceptional circumstances”.

The Irish Taxpayer is currently paying fines incurred by years of delay and distraction by the ESB. These fines (increasing by €15,000 daily) are now accruing to over €17 million and with the latest refusal there are no signs of this stopping.

In their decision report, the Bord concluded that the application did not meet the criteria for substitute consent. The report highlighted :

  • The significant effects on the environment and significant permanent residual effects were clear, profound and unacceptable and therefore the windfarm development did not meet the exceptional circumstances criteria for a substitute consent application
  • Because the environmental effects were significant and permanent and the residual impact could not be fully mitigated, the windfarm development would not have adhered to the proper planning and sustainable development regulations.
  • The remedial works after the peat slide event did not mitigate the significant environmental impacts enough.

In summary :

  • The application didn’t meet the Substitute consent criteria
  • The windfarm development shouldn’t have happened in the first place – there were too many potential
  • The remedial works done since the peat slide just weren’t enough

One one hand the ESB were consistently pushing the argument that there were no significant detrimental impacts (with mitigation) while on the other hand in 2021 they installed a sign on the windfarm site in 2021, warning of risk of peat instability from turf cutting – essentially halting mechanized turf-cutting and impacting turbary rights – again with no consultation with anyone.

Deteriorating situation

The process has been very lengthy and the ESB have been called out once again on their inability to deal respectfully with local communities as the refused time and time again to engage with community stakeholders.

The ESB needs to be held accountable for the central role they played in Ireland amassing such as significant fine. They have ignored EU recommendations to engage with community stakeholders and have now lead us up a very expensive path with which have little or no options to turn to.

It’s time for or elected representatives to demand some accountability from the ESB management team in their approach to this situation.

The failure of ESB to successfully obtain a substitute consent application has now meant years of delay and no exit from our current predicament where fines of €15,000 are building up daily. (See Derrybrien Windfarm Penalty Tracker)

So we are now in unprecedented area. Nobody actually knows what’s the next step. ESB management have been keeping a very tight reign on their process and the complete lack of transparency means that nobody (except ESB) has a clue to their next step. We are not even sure if the ESB knows the next step. This is a fundamental question that our representatives need to ask.

Given the ESBs cavalier and entitled approach to resolving this situation, the expectation is that they will now pour more money into doing a judicial review and challenge the decision of on Bord Pleanala. Expect another rise in your electricity bill as ESB continue to use you fund this disaster.

Legality of the project

Loughrea solicitor Dan Shields who represents several clients in this controversial saga, has again questioned the legality of the project.

“It is a very significant decision by An Bord Pleanála and requires due consideration. It certainly casts major doubt on the legality of the project and we are currently investigating that.”

The Bord Pleanala decision is that the Derrybrien windfarm development would not have adhered to the proper planning and sustainable development regulations lends weight to the argument. In fact, without consideration of environmental factors also, as the Derrybrien Windfarm development started prior to the planning permission decisions being met – it became an unauthorized development.

Any development which requires planning permission and does not have that permission, or which is going ahead in breach of the specific conditions set out in its planning permission, is classed as ‘unauthorized development’.

Galway City Council

Construction started in July 2003, and some of the conditions were only met in September/October 2003 and in fact when the landslide occurred some conditions were still not met.

ESB has argued this case that there was never an enforcement order served – But then again Galway County Council were the ones to grant permission in the first place so they weren’t beating down the ESBs door. If it was you or me that had an unauthorized development – it would be a different story.

From the simple definition of ‘unauthorized development’ given by Galway County council – its is irrefutable that the windfarm was an unauthorized development

Given this and the now damning decision by an Bord Pleanala – the Derrybrien windfarm could in fact now be both an unauthorized development and illegal development – moving into a very vague area.

Community Power

There are no real winners in this scenario. An Bord Pleanala have indicated that damage has been done -permanently to the environment and that the mitigation hasn’t been enough. This isn’t good news for the different community groups as its been too late to avoid the damage.

The Irish taxpayers are the ultimate losers here as the fines are mounting to over €17 million and there is now no end in sight. In fact this is what the current mounting fines will look like:

ESB has lost it’s already low credibility to be able to resolve this quickly.

The only positives that can be drawn is that the community groups have been vindicated for standing up the big corporate powers like ESB. The EU have pointed out the ESBs wrongdoing and now ABP has drawn a distinct line under this that clearly states the wrongfulness of their approach.

Lessons Learned?

The ESB (ESB Networks, Electric Ireland) on paper present themselves as a benevolent community-oriented organization that want to create a sustainable future – but from the perspective of many South Galway communities – nothing could be further from the truth as they appear as an over privileged corporation that treats communities as annoying obstacles to their goals.

Until the ESB learns its lessons and changes it’s culture then we can expect to see a wave of Derrybrien’s in the near future. Ireland plans to double its onshore wind energy production by 2030 (National Development Plan 2021-2030).

For example, even today another Windfarm proposal is causing controversy and was discussed in the Dail. A windfarm application has been passed by An Bord Pleanala, despite being refused planning permission by Cork County Council which will be located close the stunningly beautiful Gougane Barra in Cork.

With the Turbines 178m tall (that’s right) Some of the local communities will soon have to deal with Shadow flicker from the turbine blades for 20 minutes on a daily basis – but then again – who cares ?

Sounds like more of the same to me.

-David Murray

South Galway Flooding solution slow but within reach

We’ve had a few near misses since the off-the-charts devastating floods this time 6 years ago. This is a snapshot of what was flowing through Michael Cahill’s farmyard at the time.

This project is vitally important for so many of the communities of South Galway. This isn’t a sprint (even though we’d like one) – it’s a marathon! In the wider context – the proposal of flood relief channels has been raised since the 1960’s and we’ve broken new ground on this. We’ve been waiting decades and now waiting 1-2 years seem that it’s ‘within reach’. It’s been very frustrating for many in the community as flood frequency and levels are causing serious impacts of people livelihoods and health. Where are we now exactly?

  • Detailed analysis of the overall problem, flooding, levels, flows and connectivity, has been completed.
  • A feasible solution has been identified (At a high-level) that matchs Cost-Benefit and environmental constrains. This is the emerging preferred scheme
  • A highly engaging public consultation in 2021 has occurred despite Covid-19 challenges
  • More precise engineering details are now been worked out – taking in Public consultation feedback, refining channel depths, finding out soil consistency etc.
  • There are now more detailed field assessments and environmental surveys being carried out on the emerging preferred scheme to ensure that environmental aspects are fully considered.

That’s how far we have gotten until now. The main steps in 2022 (From recent Project Status report) :

  • Complete all surveys/analysis/reports for the preferred scheme proposal with an Environmental Impact Assessment Report (EIAR)
  • Final Public Consultation at the end of the 2022

That will then mean looking at Government and Ministeral approval in 2023 and hopefully that means we can kickstart then.

We all would of course have liked this yesterday but this project has been progressing through many challenges (from underlying complexity through Covid-19).

The main thing is that it is continuously progressing and we are heading in the right direction. All we can do is hope that this solution can be put in place before we get another devastating flood.


We would like to acknowledge the people with the teams working on this, from Galway County Council (Especially Enda Gallagher) and OPW, Ryan Hanley, Mott-Macdonald and our local Councillors monitoring this on a monthly basis.

Also, we would like to acknowledge the board support from landowners throughout this process.

Finally, this project wouldn’t be happening without the general support from the South Galway Communities. Every share, comment, like on Social Media does makes a difference in keeping this a priority and in focus. Thanks and please continue to support.

David Murray, on behalf of South Galway Flood Relief Committee

South Galway Flooding Update – November 2021

As site investigation works progress in South Galway, we take a look back at the progression throughout 2021.

Site investigation works progressing in South Galway

2021 brought us through the next stage of the progression of the South Galway Flood Relief. This time last year a potential solution was identified that met the required Cost-Benefit Criteria and Environmental criteria for the the project. 2021 was focused on getting presenting emerging options to the public, getting feedback and then refining these to a a preferred scheme involving channels, culverts etc. An Preferred scheme then need to have an Environmental impact Assessment Report prepared which involves a substantial amount of surveys, investigations – So there has to be a pretty good idea of the overall flooding solution.

Emerging Preferred Scheme

In February 2021, the South Galway Flood Relief Project team released a feasibility study and an emerging preferred flood relief scheme, together with supporting flood risk mapping and drawings. This was a substantial report with flood risk maps, emerging solutions and needed public consultation to get feedback on some of the options.

Public Consultation

In March 2021, the project consultants kick-started the public consultation but due to COVID-19 restrictions, the consultation initially took place online. However, with the immense amount of technical data that was produced for the proposals and with a clear demand to meet the team on site, the public consultation was extended for 8 weeks to enable on-site visits by the project team with landowners.

The extension was a success as there were over 40 site visits made and a significant amount of landowners involved who were able to talk directly with the project teams and express their concerns. The project consultants created a list of Frequently-Asked-Questions to help address this. Concerns were raised on channel and route, on Target Maximum flood levels (TMFL), fencing, maintenance, compensation etc. This consultation phase finished on 25th June 2021.

Detailed Analysis

The project teams then needed to investigate some of the issues and recommendations raised during the public consultation feedback. This then required additional localised modelling and other queries required the development of more detailed specifications (for example fencing proposals and access details across channels). There were clarifications requested on the compensations mechanisms (which is via the Arterial Drainage Act). The following is an example of some of the analysis works addressed since the public consultation process :

  • Modelling along the entire scheme, incorporating proposals and observations submitted during the public consultation. All modelling works and proposals will form part of the ‘Options Assessment’ that is required under the EIAR.
  • Fencing – details of fence types have being developed and more information gathered during site investigation works are informing additional requirements.
  • TMFLs – levels will be reviewed when results from ecological surveys / modelling have been finalised. Turlough habitat surveys and salinity levels in Kinvarra are the main inputs required to finalise TMFLs.
  • TII have engaged a 3rd party to review the M18 proposals put forward under the scheme. The project team are awaiting feedback from the TII.
  • The project team is also engaged with TII on proposals for the N67 in Kinvarra

Site Investigations

Site Investigations in Skehanna Nov 2021

With the public consultations giving rise to different options, the emerging preferred route needed to be analyzed , remodeled and also more details would be required to understand the type of soil/rock along the route.

In October 2021, Irish Drilling Ltd was appointed to carry out the geo-technical investigations. Site Investigation works commenced Monday 01/11/21 and work crew are looking at emerging routes identified in Feasibility study and with public feedback.

There has been additional reviewing/clarification of proposals that land owners indicated a preference for. The consultants will be referring back to other land owners as further proposals are developed and tied down.

EIAR/Surveys

One of the key items of this part of the development is an Environmental Impact Assessment report (EIAR) which requires substantial level of detail and analysis to ensure that the project is complying with European directives. The main work is completing environmental surveys along the emerging route. The EIAR, is now on the critical path of the programme.

Timeline

At time of writing the following is the current plan:

  • The EIAR is scheduled to be completed in June 2022
  • There will the be Public Exhibition of the Preferred route scheduled for Q3 2022.

From the last program timeline – this is yet another 6 months delay that has dogged this project from the start.

Progress

As highlighted before, it’s understandable that as this is a substantially complex project things can be slower than expected. Covid-19 has played it’s part, in slowing things down. From looking at the work done over the past few months there another aspect that’s slowing things down that it very important to highlight – ‘Adaption‘.

At various stages of the project, there has been different inputs from hydrology, environment, local knowledge, landowner input that has required a refinement and adaption of the solution. There are many cases since the last public consultation where landowner feedback has indicated alternate route preferences and if these have led to re-modelling and analysing these options.

This will add delay to the project, but if this leads us to better decision-making with consideration to our local landowners, then we should have a better and more acceptable solution – so maybe its worth it. On the other hand the more we delay the more likely it will be that South Galway will experience another flooding catastrophe. A difficult thing to reconcile.

The emerging route and some alternatives are feeding into the preferred scheme which will the the focus of the EIAR and that’s going to take another 6 months to finish surveys and compile.

Progress

The key thing is that the project has never stalled , despite Covid- it is always progressing and its progressing in the right direction. It’s very challenging project but there’s a very good dedicated team driving it.

The site investigation works have been seen by the various communities as a positive step – it’s great to see diggers on the ground, albeit for initial surveys, not flood relief works but it serves as a reminder of progress on this project.

We can only hope that South Galway can escape flooding for the next 2 years and we can then see the real ‘diggers-on-the-ground’.

M18 Motorway design not future-proofed for flooding

Following recent public consultation and the emerging preferred scheme, it has come to light that TII (Transport Infrastructure Ireland) , also known as NRA (National Roads Authority) made some significant blunders in the motorway design and construction at Kiltartan/Raheen that may have significant impacts on flooding in the area in the future. The flooding sensitivity and unpredictability highlighted by locals and the OPW was not considered in the design of the flooding mitigation and there was a lack of future-proofing that will now pose challenges to the South Galway Flood Relief Scheme

Flooding Concerns Highlighted

Before the severe flooding in November 2009 locals David Murray and John Nolan met with the National Roads Authority (NRA but now TII) and highlighted concerns of building the M18 Motorway across a flood overflow path that happened in previous years between Kiltartan, Corker, Raheen and into Coole.

Flood overflow path through Kiltartan, Corker, Raheen and then into Coole

After the severe flooding in 2009, David Murray compiled a report that outlined the flooding dynamics in Kiltartan and the concerns, if the motorway was going to go ahead, to ensure properly sized and placed culverts to account for this overflow. This report include maps, videos and photos of the flooded area.

Excerpt of the report

The report (referencing the New N18 (M18) outlined various concerns.

Properly sized and placed culverts would allow water to flow eliminating buildup of hazardous flooding levels. One beside Eugene Nolan’s house in Corker and an upgrade to existing culverts at Raheen. These culverts would be needed in addition to culverts on the new N18. As this route will be modified during new N18 development, it could make sense to include these modifications.

Kiltartan Flooding Report, March 2010

The report was sent to the NRA and others along with various emails and it was indicated that these would be taken into consideration by the ‘experts’ on the scheme.

The concerns have been raised in regard to building of the new N17 to ensure that this overflow can be handled with properly sized and placed flood culverts.

Kiltartan Flooding Report, March 2010

This was highlighted to the NRA in 2010 who were still designing the motorway. Additional communications also questions the flow rates used in the design but the culvert designs were deemed sufficient.

Upgrading Kiltartan-Corker Culverts

There is a history of flawed flood mitigation works in this area 1995, where the road was continuously raised to keep traffic open but which eventually became a dam that contributed to flooding of Kiltartan Church. See previous article: Flood Alleviation – What happens when our experts get it wrong?

An additional report to the OPW after the several 2009 floods, highlighted the flooding situation in Kiltartan highlighted the ongoing saga of raising roads without putting in culverts. The Kiltartan-Raheen Road was raised 3-4 times since 1995 and which subsequently created a dam that kept water back in Kiltartan and contributed to flooding of Kiltartan Church. This was as indicted below.

The OPW did the analysis and looked at levels where it became very obvious on how much the road had been raised in the past. Here the red lined ‘mound’ that holds the Kiltartan-Raheen road has been raised continuously since 1995.

Levels taken from Appendix 1 of he Kiltartan Flooding Report January 2011

The recommendations in the report was to install culverts through this ‘mound’ as follows:

The key things to note here is that

  • The invert-level (or Base level) of the Culvert is 11.74m (Above Sea level)
  • The cluvert installed was too small to take subsequent flows (2015)

The OPW report concludes as follows:

It is considered absolutely essential that the design of the new motorway take into account the water dynamics at Kiltartan so as to avoid any flow restrictions. The flow to be considered while designing the motorway was determined under this report and found to be approximately 100m3/s.

Kiltartan Flooding Report January 2011

The report also recommended the following :

M18 Design Flaws

It now appears that there were significant design flaws in the motorway culvert designs. From data obtained during public consultation – The levels of the culverts installed 700m downtream in the M18 Motorway were higher than the upstream culverts on the Kiltartan-Raheen road. In fact the base (invert) level of the lowest culvert under the M18 motorway at Kiltartan is over 2 ft above the base level of the upstream Kiltartan-Corker Culvert, meaning that the water would have to rise just under 2ft way up the culvert before it would work.

Here you can see the lowest Culvert Base at 12.4 M (above sea level/OD) where as the culver based in Kiltartan-Corker is 11.74m, and Corker -Coole Culvert is 10.43m.

TII/NRA may defend themselves and say that the motorway culverts were aligned with the topography of the land in question but this doesn’t really hold. Why were the culverts not aligned (or below) the level of the overflow?

  • There was already a land profiling works done after 2009 flow
  • In 2015, it was again obvious that the culverts and profiling weren’t working as water was backing up
  • Flooding in South Galway has been deteriorating and unpredictable. There were no provisions made about future scenarios
  • It was highlighted that Kiltartan was a ‘Pinch Point’ in the overall South Galway Flooding Dynamics

TII can claim that they were not making any additional changes to the hydrology of the area but what there were doing was constructing a substantial obstacle for any future works. If they were worried about unpredictable and changing hydrology, surely the topology of the land itself would have restricted flows and they could have installed culverts at a lower level to at least align with the Kiltartan-Corker culvert (which was at 11.74m) .

It is clear that the M18 Culverts at Raheen were not designed with consideration of local concern, OPW concerns and the future of the area in mind

Keeping ‘things as they were’ in an area where the flooding situation has been deteriorating for the past 4 decades with full knowledge of the longevity and immutability of a Motorway is poor reflection of road engineering and TII and will now likely incur a significant cost.

South Galway Flood Relief Scheme Recommendations

The emerging preferred South Galway Flood Relief Scheme Feasibility has indicated that the M18 Motorway will need a new large culvert to take something like 40m3 of flow. The report defines:

Augmenting the culvert capacity under the M18, e.g. installing a new 45m long 7.5m x 2.5m culvert complete with headwalls and with invert of 11.1mOD (invert designed to be lowered if necessary).

So there it is, in black and white, the base level of the culverts will be 11.1m (or lower) and will need to be 7.5m wide and 2.5m high. In the current scheme of culverts, it will look like this:

What is the impact of doing nothing:

According to the feasibility study, if the existing M18 culvert capacity is not augmented and only the flood relief channel works undertaken, the 1:100 flood levels in Kiltartan and Corker would rise over 2 ft. over the proposed targets and scenario and properties at properties at Corker and Kiltartan would be under significant flood threat. This is a scenario that must be avoided.

What is happening now?

So is this work part of the South Galway Flood Relief Scheme? According to the feasibility report, this is ‘Under Review’ but the onus and cost of adding this new culvert must come under responsibility of TII. They commissioned the design, they were notified by local people and OPW about the flooding risk and they built their culverts at a level that is too high to allow further flood mitigation. The installation of these new culverts at the right level needs to be done and paid for by TII and must not be allowed to threaten the delicate cost-benefit ratio and the viability of this scheme.

Flooding in Kiltartan has been exacerbated in the past. Roads were installed across overflow routes without proper consideration of volume and flooding levels and churches and land flooded. Once again Kiltartan is in the same situation as now a motorway has been installed without proper consideration of volume and flooding levels. TII now has a responsibility to fix this flawed design.