Comments to Draft Guidelines on Wind Energy Developement and EU Nature Conservation

General comments to

”Draft Guidelines on Wind Energy Developement and EU Nature Conservation Requirements” (Draft 17 June 2008)

The Danish Energy Agency under the Ministry of Climate and Energy, DONG Energy and Vattenfall; 22 August 2008

Denmark has 17 years of experience in the development of offshore wind energy. Denmark has 8 established OWFs of which 2 can be considered large scale. Two more large scale OWFs are in the construction phase. Comprehensive environmental studies have been carried out on the established large scale OWF (refered to in the draft), studies which will be followed up by relevant studies on the OWF under construction.

We have three problems with the draft guidelines: 1) they convey a level of concern about a conflict between wind energy developments and nature conservation interests that is out of proportion with existing knowledge, 2) important and – especially – recent studies are not included in the evaluation of impacts, and 3) chapter 5 is very unclear with respect to scope and context of recommendations.

Exaggerated concerns

For the guidelines to be useful, and gain broad acceptance, there is a need to present a more objective, balanced and up to date view of potential conflicts between wind energy developments and nature conservation interests. Given the imminent threats to nature conservation interests by climate change, there is a need for a “sober” voice. In that context, we also find it very unfortunate that the wind project developers haven’t been more involved in preparing the document, as they have hands on knowledge of the issues, and ensure a broader acceptance of its recommendations.

Some examples to illustrate this point are listed below.

Demonstrated biodiversity impacts

It is stated, as a matter of fact, that wind energy developments have been shown to have significant negative impacts on biodiversity:

”There is indisputable evidence of negative impact on biodiversity values from inappropriate locating of wind energy developments.” (page 4 – summary); “However, there is also evidence to show that the inappropriate location of wind energy developments can have a significant negative impact on biodiversity values.” (page 4 - text); “Clearly, adverse and non-disputable effects on biodiversity have been demonstrated.” (page 23)

However, in none of these cases are any examples or references given. As this is a very strong statement, used as the very foundation/justification of this guideline, it should clearly be elaborated on. Also, it needs to be explained, what is considered a significant negative impact on biodiversity.

Prevalence of studies

It is mentioned several places (page 23, 24, 69) that very few studies have been carried out regarding the effects of wind energy. This can no longer be considered correct, as several studies have been conducted since 2000 - several of which are long term programs. There has been an intense monitoring and research activity in DK, SE and UK, as witnessed by among others the following collections of studies:

Nysted Offshore Wind Farm (2000-2006): Link

Horns Rev Offshore Wind Farm (2000-2006): Link

Investigations in UK (2001-): Link

Swedish program Vindval (2004-): Link

Bird survey in Kalmar Sound, Sweden, at Utgrunden Offshore Wind Farm 1999-2003: Link

Habituation by birds

It is concluded in chapter 3 that indications of habituation are weak, and that conflicting evidence on this issue exists from the Danish studies – e.g.:

“Indications of any habituation are weak.” (page 23)

This represents a very pessimistic interpretation of existing knowledge. For sea ducks, that aggregate in large concentrations and therefore are especially prone to displacement effects, it has been clearly demonstrated - whenever firmly addressed - that they are willing to exploit habitats near to and within offshore wind farms. This goes for common scoter - generally considered to be the most disturbance sensitive sea duck species – at the Horns Rev wind farm, and common eider at the Tunø Knob wind farm (Guillemette et al. 1999 - see reference list below). With respect to long-tailed duck at Nysted, it is now broadly agreed, that the apparent displacement observed should be interpreted with caution, as the wind farm area probably represents secondary habitat, and the species is known to habituate to human activities elsewhere.

For swans and geese it is (in Denmark at least) the general experience, that they are able to habituate to onshore wind farms – a study documenting this is currently under publication (cf. Dr. Jesper Madsen, National Environmental Research Institute, Denmark),

Inclusion and use of existing knowledge

There are several examples that conclusions are based on older data and/or rather speculative (precautionary) evaluations of potential conflicts. In other cases, conclusions are drawn based on a single study indicative of a specific concern, whilst other studies indicating no effect are ignored or not considered important. Clearly, the document would benefit from a thorough reading by specialists in the field of wind turbines and environmental impacts.

Still, given the speed at which knowledge is currently building up about impacts of wind energy developments, the review used as the basis for these guidelines is likely to be out of date already at the time of publication. This should be clearly addressed, by making distinct reservations and calls for basing project specific decisions on updated reviews of existing knowledge – making use of adaptive management.

Some examples:

Displacement distances for birds

“Offshore avoidance of up to 2-4 km from wind farms has been documented for several species, including divers (Gaviidae) and diving ducks (Anatidae).” (page 32 – similar on page 25)

The Horns Rev and Nysted studies, which this statement refers to, indicate displacement at a maximum distance of 2 km from these wind farms – there is no (statistically backed) indication of displacement at further distances. That said, credit should be given for raising the possibility that these results could have come about by changes in food abundance as well.

Displacement of bats

“For bats displacement effects, related to disturbance at foraging habitats and commuting corridors, as well as roots, have been recognised.” (page 26 – similar page 30 and 32).

This is surprising information, which is in direct opposition to the generally accepted knowledge that bats are attracted to wind turbines – the apparent very core of the problem with bat collisions. Need to be backed by references.

Effects of operational noise on harbour porpoise and harbour seal

“The impact of operational noise on Harbour Porpoise and Harbour Seal from existing turbines (up to 1.5 MW) is presumably small, but impact of larger (and presumably noisier turbines) still remains to be studied.” (page 26 – and similar page 32)

The Horns Rev and Nysted wind farms, which the above citation refer to, consists of 2.0 and 2.3 MW wind turbines, respectively! That is, the impact has been studied for larger wind turbines. In addition, a complementary German harbour porpoise study conducted at the same wind farms (under publication, but referred to in recent Cowrie report (Diederichs et al. 2008)) have clearly demonstrated no major effects, the Nysted wind farm inclusive. With respect to seals (harbour and grey) a recent study from the Scroby Sands (UK) wind farm, with 2.0 MW turbines, also did not find any effects during operation (under publication, results presented at MAREE 2008 conference, 16-17 June in London).

EMF and fish

”The effects on fish are still poorly understood; with concern for potentially high impact on fish, especially for sharks, rays and lampreys.” (page 27 – likewise page 23 and 32)

The Danish results from the Nysted wind farm do not indicate any major effect for eel and several other fish species. A larger COWRIE funded experimental study focussing on sharks, rays and dogfish, likely to be particularly sensitive to EMF, similarly did not find indications of any major effects (under publication, results presented at MAREE 2008 conference, 16-17 June in London).

Chapter 5 scope and recommendations

This chapter is rather unclear as to what is the intended focus and context. The use of the term “Impact assessment” in the heading, as well as in the introductory remarks in the Introduction and background chapter, associates to an EIA context. This is reinforced by the use elsewhere in the document of the terms “Article 6 assessments” and “proper assessments”, both related to the EIA process. Reading the text, it becomes clear that it’s also about monitoring programmes (se specific comments below). Collection of data for EIA assessments and subsequent monitoring programs is two very different things, and in this text the two are mixed up, making it all rather confusing.

Also, it is not made clear, whether the discussion and recommendations relates to the specific cases where wind farm developments risks having impacts on Natura 2000 sites (Article 6 type of assessments), or it relates to assessments in general. This is a very important distinction to make, as the requirements for EIA’s and impact monitoring differ dramatically accordingly. We would clearly recommend that the guidelines restrict itself to the former case (i.e. article 6 assessments).

Impact monitoring recommendations

To recommend several years of monitoring before and 5-10 years after is far beyond what is reasonable to require, considering the knowledge collected during the last 8 years. Very few results indicate significant negative effects. To set such undifferentiated standards without argumentation and context (projects with possible Natura 2000 impacts or …?) appear very inflexible. Such long term monitoring could be done in the context of strategic research programs for the study of specific concerns, and not be standard practise in a normal consenting procedure. If an issue of concern is discovered during the EIA procedure, this should off course be followed up on, but the extent and type of an impact monitoring programme should always be considered from case to case.

Furthermore, often a short and well designed study can provide far better results than a long term surveillance type monitoring programme, just doing endless repeated counts of the species in question. The recommendations should instead focus on how to design and set up a monitoring study that ensures that useful and new knowledge is actually gained, by taking outset in existing knowledge and applying testable hypothesis and proper methodologies. For inspiration on alternatives to the standard BACI – surveillance - type of study setup see Guillemette & Larsen (2002), and a critical review of the present use of aerial surveys in bird monitoring programmes see Maclean et. al (2006, 2007).

Annex 1 on potential further research

Given the speed at which knowledge about impacts of wind energy developments is currently building up, an annex recommending further research is likely to be out of date at the time of publication. Furthermore, the need for further research will be site and project specific. We therefore do not consider the annex necessary, possibly even counter productive.

Detailed comments

Further detailed comments are given directly in the guideline. Below mentioned references are also used in the detailed comments.

References

Birklund, J. 2006: Surveys of the Benthic Communities in Nysted Offshore Wind Farm in 2005 and changes in the communities since 1999 and 2001. Final Report. DHI Water & Environment

Desholm, M., Kahlert, J. 2005: Avian collision risk at an offshore wind farm. National Environmental Research Institute. Biol. Lett. doi:10.1098/rsbl.2005.0336

Desholm, M. 2006: Wind farm related mortality among avian migrants – a remote sensing study and model analysis. National Environmental Research Institute and Institute of Biology University of Copenhagen.

Diederichs, A., G. Nehls, M. Dähne, S. Adler, S. Koschinski & Verfuß, U. 2008. Methodologies for measuring and assessing potential changes in marine mammal behaviour, abundance or distribution arising from the construction, operation and decommissioning of offshore windfarms. Commissioned by COWRIE Ltd. - report link

Erickson, W.P. et al. 2001: Avian Collisions with Wind Turbines: A Summary of Existing Studies and Comparisons to Other Sources of Avian Collision Mortality in the United States. Western EcoSystems Technology Inc.

Guillemette, M., Larsen, J.K. & Clausager, I. 1999: Assessing the Impact of the Tunø Knob Wind Park on Sea Ducks : the Influence of Food Resources. National Environmental Research Institute. NERI Technical Report 263 - report link

Guillemette, M. & Larsen, J.K. 2002. Postdevelopment Experiments to Detect Anthropogenic Disturbances: The Case of Sea Ducks and Wind Parks. Ecological Applications (12): 868-877.

Leonhard, S.B., Pedersen, J. 2006: Benthic Communities at Horns Rev Before, During and After Construction of Horns Rev Offshore Wind Farm, Final Report. Bio/Consult AS.

Maclean, I.M.D., Skov, H., Rehfisch, M.M. and Piper, W. 2006. Use of aerial surveys to detect bird displacement by offshore windfarms. BTO Research Report No. 446 to COWRIE. BTO, Thetford. - report link

Maclean, I.M.D., Skov, H. & Rehfisch, M.M. 2007. Further use of aerial surveys to detect bird displacement by offshore wind farms. BTO Research Report No. 482 to Cowrie. BTO, Thetford. - report link

Madsen P.T., Wahlberg M., Tougaard J., Lucke K. and Tyack P. 2006: Wind turbine underwater noise and marine mammals: Implications of current knowledge and data needs. MEPS. 309: 279–295

Petterson, J. 2005, The Impact of offshore wind farms on bird life in Southern Kalmar Sound, Sweden. A final report based on studies 1999-2003.

Wilhelmsson, D., Malm, T., Öhman M.C. 2006: The influence of offshore windpower on demersal fish. ICES Journal of Marine Science, 63: 775e784 (2006). - report link

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