Farm Energy claims that the risk to Golden Eagle is insignificant but its environmental assessment is inadequate (see below). The impact on Golden Eagle can only be properly assessed by a thorough and open examination of the facts at a public inquiry.

DRAFT TEXT

Subject:

WIND TURBINE DEVELOPMENT ON A SITE DESIGNATED UNDER NATURA 2000 AND THE RAMSAR CONVENTION 

By electronic mail to Mr Ed Swanney Scottish Executive

Dear Mr Swanney,

We have been informed that Farm Energy Ltd has applied for planning permission to erect six wind turbines on Beinn Mholach inside the Lewis Peatlands Special Protection Area, Isle of Lewis, Scotland, in close proximity to nesting Golden Eagle (site also designated under the RAMSAR Convention). This project is referred to as "Pentland Road" by the promoters, but in fact it is on the Barvas Hills, well into the SPA.

Wind turbines do not have to be located in Special Protection Areas. The Golden Eagle is well known to be highly susceptible to turbine blade strike (more than 1000 eagles have been killed in Altamont, California, over the last 20 years) and there are sufficient other significant threats (e.g.: persecution, poisoning) to the Scottish and European populations.

This development sets an unacceptable precedent for the imminent planning application by AMEC Project Investments Ltd for 300 potentially lethal wind turbines inside the same Lewis Peatlands Special Protection Area.

Farm Energy claims that the risk to Golden Eagle is insignificant but its environmental assessment is inadequate. The impact on Golden Eagle can only be properly assessed by a thorough and open examination of the facts.

This is a matter which causes grave concern among UK and European conservationists. With reference to P/PP/75/96/W/6 we request therefore that you initiate urgently a public inquiry.

Yours sincerely,

(Name and address)

Key problems with Farm Energy's Golden Eagle assessment:

·           the assessment predicts one eagle death every 46 years using a model provided by the wind industrys trade lobby (British Wind Energy Association), despite the fact that the Scottish Executive has advised that this model is unfit for the purpose;

·           the blade strike estimate is reduced by claiming that golden eagles avoid wind turbines. In fact research demonstrates that golden eagles are attracted to wind turbines, spending seven times more time flying in close proximity (within 50m) to wind turbines than would be expected by chance.

·           observations to determine range use took place in May and June only, an atypical period when breeding eagles are expected to remain close to their nest and an abundance of prey readily available close to the nest. Range use in May and June does not extrapolate to range use for the rest of the year.

·           the assessment notes the Golden Eagles preference for land more than 150m above sea level, but uses an arbitrary distance from the nest to just exclude the wind farm site from the definition of the eagles core range. Land over 150m above sea level is limited in the locality and this wind farm is in the eagles core range.

Citations for the Lewis Peatlands Special Protection Area:

58,984 hectares. Designated under EC Birds Directive 79/409/EC site UK9001571 and RAMSAR Convention site 1046. A near-continuous mantle of deep blanket peat liberally dotted with small pools and lochs, the second-largest expanse of this habitat in the UK, and one of the largest in Europe. Similar in character to the peatlands of Caithness and Sutherland which were extensively damaged by coniferous afforestation in the 1980s. To the south, the peatland is more broken, with outcrops of rock and larger lochs forming a distinctive "knock and lochan" landscape. The hyper-oceanic, extremely humid upper boreal bioclimatic zone predominates here to an extent found nowhere else in Europe.

This vast expanse of relatively undisturbed peatland supports a diverse range of associated flora and fauna, and is internationally important for migratory birds and for breeding waders, divers and raptors, including:

·           Dunlin                                33.2%    Baltic/UK/Ireland breeding population

·           Golden Plover                   8.8%       UK breeding population

·           Black-throated Diver      6.9%       UK breeding population

·           Red-throated Diver         6.4%       UK breeding population

·           Golden Eagle                    1.5%       UK breeding population

·           Merlin                                 1.5%       UK breeding population

·           Greenshank                      10.0%    UK breeding population