ANNEX C
to Appeal to European Commission
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 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 renowned 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 borne in mind that 1,000 to 2,000 Golden Eagles have been killed by wind turbines at this Californian windfarm
over 20 years (2)
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 (3). 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, sparrowhawks and kestrels. (4)
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 (5), 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 for EDINBANE:
How many eagles are likely to 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 Eagles (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. (6)
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. (7)
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, Para. 3.15
(8)
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 those of SNH) -
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. This presupposes
that SNH and windfarm promoters are 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 required. And that could be 15 eagles or less, as required by SNH.
Why the figure of 15? 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 SNH does not say that:
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 Harrier and Merlin, both breeding on the site itself. Yet,
in the same 60 hours of observation at Edinbane-proper, 12 flights of White-tailed 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 with the Golden Eagle relationship, and this
is close enough to provide an order of magnitude.
To put things into perspective: there are currently only 32 breeding
pairs of White-tailed Eagles in the UK, all of them in Scotland.
Here again the factor cumulative effect must
be taken into account. We have seen above that White-tailed 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
Eagles, the extirpation of the species from Scotland (and therefore the UK)
is very much a possibility in the medium to long-term. SNH has not addressed this aspect at all. Neither for Edinbane, Eishken,
the Lewis SPA, Pairc, Inverliever, nor for any windfarm project which targets White-tailed Eagle habitat.
With so
many windfarm projects in the pipeline, it is not surprising that windfarm promoters do not want to discuss the cumulative
impact on Scottish birds.
It is however SNH’s responsibility
to do just that!
|
