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energyconsents@scotland.gsi

OBJECTION TO THE PAIRC WINDFARM PROJECT - HYDROLOGY INTEREST

ISLE OF LEWIS, SCOTLAND

PROMOTER : SCOTTISH AND SOUTHERN ENERGY




Dear Scottish Ministers,

Please register my objection to the above project, for the following reasons :



A ) A MASSIVE IMPACT

The windfarm area is huge. It spreads over 5,000 hectares ( 50 km2 - ES 14.5.1 ). It includes 120 km of watercourses. It comprises 544 lochs, lochans, and dubh lochans, accounting for 8.5% of the study area - ( ES - 14.5.7 & 8 ). This, and minimal human disturbance, makes it a perfect habitat for otters, divers, geese, swans, eagles, merlins, harriers, and various other protected species.

This wildlife paradise will be devastated : “ The proposed Pairc wind farm will comprise 57 wind turbines with mass concrete foundations. The windfarm infrastructure will comprise transformers, on-site cabling, a switching station/control building, 33kV underground cables, temporary and permanent anemometers, crane pads, access track, site tracks, up to 10 borrow pits and crushing plant, three temporary construction compounds and laydown areas, concrete batching plant and improvements and modifications to public roads ” ( ES - 14.6.1 ).

The ES won’t tell us how many kilometres of site and access tracks will cut through the live, fragile and valuable peat . We are told, however, that there will be 88 stream crossings ( 39 + 49, says the ES - 14.6.1 ). It is clear that the impact will be massive .



B) SPIN

The effect of the ES is to minimise our perception of the devastation. Spin is applied in a crafty way through a "significance matrix" based on arbitrary judgement . It makes a mockery of the precautionary principle.

The idea is to transform, say, a risk of " high accidental impact " into a " minor anticipated residual impact " .

It comes down to obfuscation and manipulation, i.e. spin . Example :

" During the construction of the windfarm there will be a number of activities taking place that could impact upon surface waters. A number of potential pollutants will be present on site, including oil, fuels, chemicals, unset cement and concrete as well as waste and wastewater from staff facilities. Any pollution incident occurring on the site may adversely affect the quality of nearby surface waters.
Without the proposed mitigation measures described above, the magnitude of a pollution incident has the potential to be major and the likelihood of such an incident occurring likely.
With the mitigation measures in place the potential magnitude will be reduced to moderate and the likelihood to unlikely, making the anticipated order of effect minor."

The "significance matrix" being used is little more than arbitrary judgement dressed up as science .

For indeed, what does that miraculous mitigation consist of ?
- A long list of promises , summarised by the words : " a rigorous pollution prevention plan ".


No doubt the crew of the Exxon Valdez also had in hand a « rigorous pollution prevention plan » .




C) THE OIL THEY FORGET


They further state : “ However the windfarm layout has been designed such that bulk fuel and chemical stores will be located at the site compound, outside the public supply catchment and therefore no pathway to the public supply intake could be established for any spillage occurring at the site compound. That part of the windfarm development located within the supply catchment is sited at the head of the catchment, over 1km from the intake. Any spilled pollutants would have to travel this considerable distance, via a number of lochs before reaching the public supply intake and would be subject to significant dispersion and dilution. In addition a rigorous pollution prevention plan will be implemented. ”

- There are not one, but 3 public water supplies within the study area." ( ES - 14.5.10). Besides, oil does not "dilute" in water : it remains in its form, and travels .

As for the concentration of pollutants at the site compound, they forget to say that each wind turbine contains about 400 litres of oil , a lubricant that needs to be changed every now and then ( at 3-year intervals, I was told ). The risk of spillage is thus multiplied by 57 ( turbines ), and then by 8 ( 25 years divided by 3 ) - more still if the windfarm is repowered at the end of its life .

Besides, some of the spillage may not be “accidental” : it may be voluntary - e.g. workers wanting to get home early to watch a football match, and having no time to transfer the used, dirty oil into the proper disposal unit located kilometres away .

Leaks too may develop :
PICTURES OF OIL LEAKS

Many spilling incidents go unreported, but in Germany 8 are already on record: Accidents click "Accident Statistics" in the left margin, read if you wish, then go to page bottom and click "here" for the full list, then scroll down to these items:

quote

- 123: oil leaks into ground - specialist firm called to clean up
- 188: oil leaks into ground - ongoing for a month - attempts to capture with granules failed
- 195: turbine destroyed by storm, oil spilled in protected area for drinking water supply - possible prosecution...
- 198: oil leaking into ground during several days
- 205: 160 litres of oil leak in protected area for drinking water supply, and some is scattered by the blades over a wide area
- 261: Loss of hydraulic fluid into surrounding ground. Serious concerns over environmental pollution from all three turbines. Talk of prosecution.
- 278 Significant contamination of the site and surrounding ground from leaking oil. Transmission oil leak down the tower and also out across the blades, which scatter it around.
- 342 The tower crashed. There was spillage of a large quantity of transmission oil.


unquote

Items 195 and 342 are particularly interesting because there have been many such crashes around the world. Lubricating oil being stored in each nacelle ( or "gondola" ), it follows that this contaminating lubricant will normally spill into the ground after a crash. - This further increases the overall number of oil contamination occurrences. But here again the Pairc ES keeps silent about it.

A long list of turbine crashes and fires may be found on the same webpage :
Accidents - see above for access details.

Reviewing the accidents individually, we find item 55 relating the collapse of 129 turbines in a major storm in India. This is a bit extreme, but even outside cyclones areas there has been a substantial number of turbine collapses, plus many of fires, blade throws, ice throws and other accidents ( quite a few hundreds worldwide, according to the same source - see their list ).

A few pictures may be seen here :


CRASH1
CRASH2
CRASH3 (NZ - the title is in French, but the text is in English).
PICTURE GALLERY OF CRASHES AND TURBINES ON FIRE select photo album under pictures to the right of the page. To enlarge the lot, click "comments" under any picture.



In addition, underground cables between turbines need to be oil-cooled, and leaks are possible/likely.




D) THE CLEANING LIQUIDS THEY FORGET

As part of maintenance, the blades of the wind turbines need cleaning, for their performance is impaired when dead insects form a paste on their surface. The columns also need a good wash when their aspect is marred by oil leaks ( also a way of making the evidence disappear ) . A water cannon is used, as shown on the pictures here :

TURBINE WASHING PICTURE

TURBINE WASHING PICTURE 2



Cleaning liquids are thus spread into the wind, and ultimately on pristine blanket peat habitat, and into streams, lochs and lochans .




E) DRINKING WATER


" Three public water supplies have been identified within the study area." ( ES - 14.5.10). But with the use of the significance matrix, " the anticipated residual impact will therefore be minor ". ( 14.6.5 (c) )

Should we trust the "significance matrix" ( or spin matrix? ) where the health of the population is at stake?

And should we trust a "rigorous pollution prevention plan" ? - Didn´t the EXXON-VALDEZ have one ? Doesn´t every BHOPAL and CHERNOBYL in the world have rigorous accident prevention plans ?



By the way, it is worth noting that a windfarm project was turned down in Scotland mainly because of its possible impact on drinking water :

DRUMDERG WINDFARM DECISION

"Campaigners fighting over 250 wind-farm projects across Scotland today hailed the rejection of Perthshire´s first wind-farm application as a victory for common sense. At a packed meeting in Perth City Hall, Perth and Kinross councillors voted by 8-2 to refuse planning consent for a 16-turbine development at Drumderg, overlooking "Bonnie Glenshee" and close to the A93 tourist route to Braemar. Concerns over the effects of excavation works on the water supply to local residents and the risks to a nearby Site of Scientific Interest were uppermost in the minds of councillors who spoke against the issue."

Source: press release from Scottish Wind Watch, January 19th 2005

and :

" Earlier this month, councillors in Perth and Kinross rejected Scottish and Southern Energy’s plans for a wind farm at Drumderg because of the risk to the local water supply and wildlife, and an "adverse visual impact".

RISK TO WATER SUPPLY




F) CONCLUSION

Pollution accidents do occur, even in the most robustly-planned industrial installations. At Pairc, there are hundreds of places where contamination may occur, affecting the pristine peat bog habitat and the hydrology of this vast area : the surface affected by the windfarm is huge ( 5,000 hectares ), there are 120 kms of watercourses, 544 lochs and lochans, 88 stream crossings, 57 wind turbines, transformers, on-site cabling, a switching station/control building, oil-cooled underground cables, tens of kilometers of access and site tracks ( sources of sedimentation of lochs and streams, and oil from vehicles ), up to 10 borrow pits and crushing plant, three temporary construction compounds and laydown areas, concrete batching plant and improvements and modifications to public roads ...

The decision makers, warned in detail of the significant risks involved, could be blamed for any damage done - in civil and, God forbid, criminal courts.

A legal opinion would be a prudent thing to obtain, though the mind-set of judges may evolve once the windfarm bubble bursts.


X X X



Three more objections to the Pairc project were published here :

Absurdity is... destroying carbon sinks in the name of Kyoto

Absurdity is .... repeating the same mistake, thus causing more peat slides

Will the Scottish Government condemn the Scottish eagles to extinction ?


A final one will address the damage to tourism interests.


Yours, faithfully

Mark Duchamp.........................................24 July 2007

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