| Birds and Windfarms - The use of junk science in Scotland. |
(2250) |
| MODELS REPLACE REAL DATA IN THE DECISION-MAKING PROCESS. |
Scottish authorities, supportive of an all-out exploitation of the country´s wind resources, refuse to see the disastrous consequences of windfarms on wildlife, just as they are determined to disregard the effects on tourism and people.
The rare white-tailed sea eagle, and the emblematic golden eagle, are facing extirpation from Scotland, and therefore the UK.
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OPEN LETTER TO SCOTTISH NATURAL HERITAGE (SNH)
Subject: accomplice with premeditation?
Dear Sirs,
I wish to draw your attention to the breach of Scottish, UK, and European legislation by SNH in relation to three wind farm projects: Inverliever, Eishken, and Edinbane. Your own declared policy is also being violated.
These three cases are but an example of what is now happening across Scotland.
1) INVERLIEVER (ARGYLL)
In the first Environmental Statement of 2001 (ES), a map had been drawn recording with precision the flights of those birds that are protected by law. This map shows indisputably that golden eagles, ospreys, hen harriers, red-throated divers and black-throated divers use the site where the promoter plans to erect his wind farm. It is posted here: MAP
SNH does not contest that. Neither does it contest that wind turbines are known to kill birds. But then, may I ask, why is it that SNH has not objected to the project, firmly and unequivocally?
Not only this, but SNH goes further. It is allowing the promoter to disregard this REAL evidence, as collected by his own consultant in 2001, and use VIRTUAL evidence instead, drawn from flawed modelling. Indeed, the so-called PAT model is now being produced as evidence that the site is not important to eagles.
For if the proposed windfarm site has been moved slightly towards the south west along the same ridge, the data collected in 2001 shows that the "target species" use the new site just as much, if not more - see: MAP
SNH also chose to centre its decision-making on the golden eagles. By doing so, the fate of the ospreys, hen harriers, red-throated divers and black-throated divers is being effectively disregarded, notwithstanding the fact that ospreys have been killed by wind turbines in Australia, harriers in Germany, and that the ES to the Lewis SPA project admits that divers are at risk near windfarms (ES, paragraph 236 in the section on collisions: "Twelve pairs were identified as at high risk" etc. ).
As for the golden eagles, what is being said in the new impact assessment based on virtual reality is contrary to established fact - i.e. the recorded flights as shown on: MAP
The PAT model, which is the cornerstone of the windfarm promoter´s exercise in virtual ornithology, establishes that three characteristics of the topography are particularly important on a golden eagle range:
- areas that are above 150 meters in altitude.
- open areas (as opposed to forests) where the eagles can forage.
- ridges, where declivity winds are used for soaring (and where raptors also perch).
And it just happens that the site chosen by the promoter to erect his turbines is:
- above 150 meters in altitude.
- in an open area, while much of the Inverliever golden eagle range is rendered useless by forestry - which makes the windfarm site even more important to the eagles.
- on a ridge used by the eagles and other protected raptors for soaring and perching - see: MAP
It is clear from the above that the proposed windfarm site is in a part of the range that is essential to the eagles. And flight data from the map confirm this.
One is therefore compelled to conclude either of the following:
- the model is flawed.
- its use by the consultant is faulty.
- both.
Flawed model: one of the premises of the PAT is that the core range is more important to the eagles than the rest of their range. Yet, the definition of "core range" is that area close to the nest where the raptors spend 50% of their flying time.
The effect of this premise is to skew the model into minimizing the importance of the rest of the range, even though the eagles spend there the other half of their flying time. This distortion of reality has allowed the Inverliever promoter to declare the wind farm site as unimportant to the eagles, whereas in fact it is of paramount importance to them, being a ridge where they come routinely to soar, perch, and/or forage (as shown by the flight map, which only reflects a small number of hours of observation).
Even if the model being used were 100% valid and accurate, it would still be inappropriate - because the Inverliever promoter is able to use it to assert, to his advantage, what reality shows to be false (the ridge being unimportant to the eagles). And this would be a sure indication that the concept of modelling is inappropriate for use as a decision-making tool.
Either way, faulty or not, it is clear that the PAT model should not be used by windfarm promoters. The Inverliever example is proof of it.
CONCLUSION:
The Inverliever project is sited in the wrong location. A "management area" is no substitute for an important ridge used for soaring and perching. SNH should not, by its lack of objection, endorse the Inverliever project.
Besides, approaching each project "on its own merits" flies in the face of the basic principle of conservation, which is: cumulative effect. And no study has been made of the cumulative impact of so many windfarms to be erected in the habitat of protected bird species in Scotland.
Let us remember that it is illegal to kill golden eagles, ospreys, hen harriers, red-throated divers, and black-throated divers - among others.
There are also indications that the rare white-tailed sea eagle may settle in the Loch Awe area.
2) EISHKEN (THE MUAITHEABHAL WIND FARM PROJECT), ISLE OF LEWIS
In this instance, another defective model is being used by a windfarm promoter to convince the authorities - apparently with success.
Based on the SNH collision model, and modified in a non-specified way by the consultant, the Eishken ES predicts that as many as 9 golden eagles and 7 white-tailed sea eagles may die from colliding with the 399 turbine blades over 25 years.
I will limit myself to a few brief comments, and refer you for more details to my objection to the project, here: EISHKEN
a) The collision model is flawed. This has been demonstrated in another objection, here:
LEWIS SEE SECTION 1.1
b) Mortality will be substantially higher than represented for the 2 species of eagles, plus 8 additional protected species present on the site, (see objection in (a) above).
c) NSA and IBA: the windfarm is to be erected in a National Scenic Area and a designated Important Bird Area (IBA UK224 - see objection).
d) 10 % of the UK population of white-tailed sea eagles: IBA UK224 is home to 7 white-tailed eagles. This makes the Eishken estate a stronghold of the species in the UK. As such, it should have been designated "Special Protection Area" in accordance with EU Bird & Habitats Directives.
e) 11 pairs of golden eagles: IBA UK224 is also home to 2.5% of the UK population of golden eagles (2.5 times more than the Lewis peatlands SPA)
f) Other protected birds to be killed by the 133 wind turbines include: merlins, peregrine falcons, red-throated divers, black-throated divers, golden plovers, dunlins, greenshanks, whooper swans, white-fronted geese and barnacle geese.
f) Obfuscation and pseudo-science is being used in the environmental statement. The consultant disregards 20 years of established ornithological data and, using his own 2-year figures instead, he claims that the Eishken eagles are unproductive - whereas the 20-year record indicates the opposite to be true: the area is a source population.
g) A population sink: contrary to what the promoter wants us to believe, a windfarm at Eishken will create a black hole that will act as a drain on the eagle population of Scotland. - As resident eagles are killed by the turbines, other eagles from the Western Isles, other islands of the region, and even the mainland will replace them on their attractive "prey-enhanced" ranges - and get killed in turn.
Details here: EISHKEN
CONCLUSION:
At Eishken, SNH is being asked to approve - by not objecting - the erection of 133 proven bird-killing machines in a designated Important Bird Area that is essential to the recuperation of the rarest bird in Scotland and the UK: the endangered white-tailed sea eagle.
The death of 16 white-tailed and golden eagles has been predicted by the consultant; and in fact there will be more. Yet, it is illegal to kill any of these birds. So why isn´t SNH opposing the project? In my humble opinion, this amounts to being an accomplice with premeditation: it is for lawyers to tell.
And here again, no Scotland-wide cumulative impact study was conducted - either for the 2 species of eagles, or for the merlins, peregrine falcons, red-throated divers, black-throated divers, golden plovers, dunlins, greenshanks, whooper swans, white-fronted geese and barnacle geese. SNH is not acting responsibly in this respect.
3) EDINBANE, ISLE OF SKYE (2 NEIGHBOURING PROJECTS: EDINBANE & BEN AKETIL)
Both projects are located in an area that sees an unusual concentration of
immature eagles of 2 species: golden eagles and white-tailed sea eagles.
Known by ornithologists as a dispersion area, this is where young eagles
come to forage, soar, or interact with one another, without risk of being
chased away by territorial adults.
An internationally renown example of such a dispersion area is Altamont
Pass, in California, where immature golden eagles come to feed on the
numerous cottontails and ground squirrels.
At Edinbane-proper (not including Ben Aketil), 55 flights of golden eagles
were recorded in 60 hours of observation: almost one every hour. - This is
arguably the busiest eagle dispersion area in the whole of Scotland. So the
parallel with Altamont is appropriate.
If these windfarms are erected in the Edinbane dispersion area, new
generations of eagles will be decimated like they are at Altamont. It must
be born in mind that 1,000 to 2,000 golden eagles have been killed by wind
turbines at this Californian windfarm over 20 years (1).
And Dr. Smallwood has confirmed that raptor mortality at Altamont is not
exceptional when local bird abundance is taken into account at other windfarms.
Nor is it an effect of the old model, lattice-tower turbines: bigger, tubular-tower
models kill even more birds, including many protected raptors (2). This is also
corroborated by the study made by Dr. Lekuona at the request of the Navarre
government, Spain: in one year, 368 tubular-tower turbines killed 7,105 birds,
including griffon vultures, golden eagles, eagle owls, booted eagles, sparrow
hawks and kestrels. (3)
But the example of Altamont is more relevant, being a dispersion area for
eagles, like Edinbane.
If, at Altamont Pass, 116.5 golden eagles are estimated to die yearly (4),
a lesser number will at Edinbane, because the windfarms and the eagle
populations are smaller in size. But on the other hand, at Edinbane both
projects are located on ridges heavily used by the eagles to soar,
where the impact will be maximal - see eagle flight map:
MAP-EDINBANE
How many eagles may die if the Edinbane windfarms are built? An
independent analyst, Dr. Jeremy Carter, applied the method
developed by Drs Thelander and Smallwood at Altamont to the Edinbane
windfarms, and found:
"The (Ben Aketil) applicant´s own assessment of the impact of the Ben Aketil
wind farm is that one golden eagle may be killed every 8.5 years, and
cumulatively with the Edinbane wind farm one eagle every 1.5 years. Leaving
aside the fact that the applicant´s assessment is very likely an
underestimate of the collision risk for Golden Eagle (as I have shown), it
implies that even the applicant´s estimate is that the combined impact of
these developments may be to kill 17 golden eagles over 25 years. The more
realistic direct estimate not including displacement but based on
observation at existing wind farms gives a mean of 1.9 collisions per year
for Ben Aketil, and 9.3 collisions per year for the cumulative impact,
implying that these developments may kill up to 233 golden eagles over 25
years. Whichever estimate is considered, an impact of this severity is
completely unacceptable. (5)
233 dead golden eagles over 25 years, as opposed to 17 predicted by the
applicant: the gap is huge. Although it may in part be due to the inherent
uncertainty in model based predictions, in part it certainly results from
the application of an arbitrary "avoidance rate" by the Ben Aketil promoter.
But regardless of model predictions, we know that golden eagles are being
killed in very large numbers elsewhere (the actual 1,000 to 2,000 golden
eagles deaths in the Altamont dispersion area so far). And this reality is being
discarded in favour of virtual ornithology, which is unproven, and subject to
large uncertainties. In fact, the predictions are manageable at will by selection
of the parameters.
One of the parameters in question is the "avoidance rate". It is chosen
arbitrarily: sometimes 95%, or 99%, or 99.5%, depending on the consultant.
In the case of Edinbane, 99.62% is applied, without substantiation.
In real life, evidence from Altamont shows that, far from
avoiding wind turbines, golden eagles are somehow attracted to them. (6)
Another parameter that may be easily manipulated is the "utilisation rate",
which is the number of bird flights per hour per unit area:
"Predicted blade strike risk is strongly dependent on the choice of area
used to normalise utilisation rate: including large areas with no observed
flight activity dilutes the utilisation rate and can substantially reduce
the predicted risk".
Dr. Jeremy Carter - Objection to the Lewis peatlands wind farm project,
parag. 3.15 (7)
In any event, even if there were no manipulation of input data by wind farm
promoters, we have seen that collision models are fatally flawed (any of
them, including SNH´s) - see the demonstration here:
Giant windfarm in a bird sanctuary - Impact on bird mortality to be severe. - section 1.1
It is therefore all the more worrying that SNH would have conveyed the
following understanding to the promoter of the Edinbane windfarm: we will
not object provided you predict there will be no more than 15 golden eagle
deaths. In commercial terms, this would be called: "a deal". And if no money
is involved, what has been set here is the number of illegal killings that SNH
deems acceptable. - As if SNH and windfarm promoters were above the law.
There is little doubt that, using a collision model subject to very large
uncertainties, and being in control of the parameters and data to be fed
into it, a promoter could predict the exact mortality figure he wants. And that could
be 15 eagles or less, as required by SNH.
Why 15, do you ask? Because SNH has calculated that this is the maximum
tolerable death toll if the golden eagle population of the Cuillins SPA is
to remain stable.
But here is what SNH does not say:
1) Population stability means that the Cuillins SPA will stop being a
source population, i.e. it will no longer provide young eagles to replace eagles
killed in other parts of the country. And this is one of the fundamental roles of bird reserves.
2) More windfarms are planned for the Isle of Skye, which will inevitably
kill more immature eagles roaming out of the Cuillins. And so will the added tension lines, to export the electricity produced. - It is clear that the overall death toll on the island will be superior to 15. - Here again, SNH is failing the basic principle of conservation: cumulative effect.
3) Voluntarily imposing on the eagle population of the Cuillins SPA a barely self-sustaining reproduction rate is an irresponsible act. In effect, should any other unforeseen adverse circumstance occur, the population will decline. And the list of contingencies is a long one: illegal shooting, egg-snatching, excessive disturbance by hikers (and some scientists), lack of prey, poisoning, illness, epidemics, in-breeding, fires, electrocution, collision with power lines, etc.
In any event, we have seen that any prediction that 15 eagles or less will
die at the proposed Edinbane windfarms is not credible. The real number,
based on real data, is likely to be much greater. And the effect of such
mortality on the eagle interest of the Cuillins SPA will be devastating.
Either way, 15 or 233, it is an unsustainable death toll for the Cuillins
SPA - and indeed for Scotland, for at that level we must consider the eagles
to be killed at all other Scottish windfarms, built or planned.
And golden eagles are the only ones being considered by SNH in the deal over Edinbane. White-tailed eagle mortality is disregarded, even though it was not appropriately addressed by the consultant - nor is that of other "protected" raptors: hen harriers and merlins, both breeding on the site itself. Yet, in the same 60 hours of observation at Edinbane-proper, 12 flights of white-tailed sea eagles were recorded.
Extrapolating from the golden eagle mortality figure of 233 predicted from
the known data from Altamont, this would yield a white-tailed eagle
mortality of 50.8 over 25 years. This extrapolation, based on Edinbane/Ben
Aketil predicted mortality, and Edinbane-proper recorded flights, is not
exact. But it dovetails the golden eagle relationship, and this is close
enough to provide an order of magnitude.
To put things into perspective: there are only 32 breeding pairs of
white-tailed eagles in the UK, all of them in Scotland.
So here again, naturally, the notion of cumulative effect comes to mind. For we have seen that white-tailed sea eagles will be killed at Eishken as well. And there are many more windfarms planned in their habitat, on Lewis, Skye, Mull, Ardnamurchan, etc.
With so many deadly rotors in their airspace, and so few white-tailed sea
eagles, the extirpation of the species from Scotland (and therefore the UK)
is very much a possibility, over the medium to long-term. And this is something SNH has not even addressed. Not for Edinbane, not for Eishken, not for the Lewis SPA, not for Pairc, not for Inverliever, not for any windfarm project targeting white-tailed eagle habitat.
And with so many windfarms in the pipeline, it is to be expected that windfarm promoters do not want to talk about the problem of cumulative impact on Scottish birds.
But why the total silence from SNH also?
GENERAL CONCLUSION:
SNH is failing to abide by the law, which makes the killing of eagles and other protected birds a criminal offence - especially as there are many alternative windfarm sites in Scotland where the danger would be much less significant. In fact, the most important bird areas are being targeted by windfarm developers, with little or no opposition from SNH.
SNH is failing its duties as a conservation organisation, repeatedly ignoring the disastrous cumulative effect that future Scottish windfarms, jointly, will bring to bear on bird species protected by Scottish, UK and European legislation.
SNH is permitting the use of modelling by windfarm promoters, instead of real mortality data available from existing monitoring studies. But models are fatally flawed, and in any event the management of its parameters will produce a wide range of results, from which windfarm promoters may pick the most appropriate to their interests.
Therefore, SNH urgently needs to review its current practice, which is widely at odds with its declared policy:
"The capacity of most locales, regions or countries for wind energy generation will almost always allow for wind farms to be located in areas away from important bird areas. A key question to ask, therefore, at the very earliest stage of assessment is ‘could this wind farm be located in an area where it would have less impact on birds’?"
- SNH guidelines. (8)
This is a question that SNH never asked, as not a single ES ever tried to answer it.
So I beg of you that you reconsider, and start by saving the eagles at Inverliever, Eishken and Edinbane. The only way to do that is to object strongly to these projects.
These are my personal views. I am not expressing any official position of Proact International, of which I am the Windfarm/Bird Research Manager.
Mark Duchamp...............................................March 31st, 2005
c/o Iberica 2000
Escuela Politecnica Superior de Gandía
E - 46730 Playa de Gandia, Spain
Telephone: +34 679 12 99 97
Link to prior research: The negative effects of windfarms: links to papers published by Mark Duchamp
NOTES AND REFERENCES:
(1) - Chilling Statistics SEE SECTION: 1) Altamont Pass.
(2) - "It appears that factors other than tower type play more of a role in whether a particular turbine is associated with one or more fatalities, such as prey distribution about the tower’s base, physical relief, and presence of declivity winds. Regardless, the number of fatalities at tubular towers was higher than at horizontal lattice towers".
THELANDER Bird Risk Behaviors and Fatalities at the Altamont Pass Wind Resource Area - December 2003 -Chapter 6: Discussion
Also available here: http://www.nrel.gov/docs/fy04osti/33829.pdf
(3) - Birds and windfarms - Critical analysis of 4 reports on bird mortality at windfarm sites. - SEE SECTION 1 - M. Duchamp (2003) Also available here: www.iberica2000.org/Es/Articulo.asp?Id=1223
(4) - DEVELOPING METHODS TO REDUCE BIRD MORTALITY IN THE ALTAMONT PASS WIND RESOURCE AREA - Dr. Smallwood & K. Thelander, Aug. 2004.
SMALLWOOD - Note: you must download chapter 3: Bird Mortality (11.7 megabytes) and go to page 73, Table 3.11, 1st line:
"116.5 golden eagles p.a. adjusted for search detection and scavenging."
Also available here: http://www.energy.ca.gov/pier/final_project_reports/500-04-052.html
(5) - CARTER SEE PARAGRAPH 1.14 Dr. Jeremy Carter - Objection to Edinbane & Ben Aketil wind farm projects. Sent on 23 April 2004 to Mr Bill Hepburn with the note: "these representations supplement and reinforce my original representations of 29 november and 20 december 2002"
(6) - "In practice, Golden Eagle is a species that is particularly vulnerable to collision, and indeed evidence indicates that where wind farms have been located in golden eagle habitat they are killed in numbers far greater than would be expected from their abundance. The best available study (8) of golden eagle behaviour in wind farms notes:
“…raptors spent significantly more time flying at close proximity to turbine blades ... than 51-100 m away ... or >100 m away … Analyzing the total number of minutes of flight time reveals that something about wind turbines may attract red-tailed hawks to fly near turbines and at dangerous heights. Similarly, American kestrels flew in proximity level 1 (ie 1-50m from turbine) nearly four times longer than expected by chance, golden eagles two times longer, and northern harriers three times longer".
Source: CARTER see SECTION 1.5
Reference 8 in the above quote:
Thelander, C. G,Smallwood, K.S., Rugge, L., Bird Risk Behaviors and Fatalities at the Altamont Pass Wind Resource Area - National Renewable Energy Laboratory Report SR-500-33829, 2003. www.nrel.gov/docs/fy04osti/33829.pdf
LINK
(7) - Source: Source: Objection to windfarm on the Lewis peatlands SPA. Dr. Jeremy Carter 2004 - OBJECTION -- see paragraph 3.15
(8) - This quote is from the SNH guidelines: "Annex 2 - Methods to assess the impacts of proposed onshore wind farms on bird communities - 3. General guidelines - 3.1. Location is critically important".
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por: Mark Duchamp (28/03/2005) |
| Fuente/Autor:
Mark Duchamp |
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