ANNEX A
to Appeal to European Commission
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: See MAP
SNH does not contest that. Neither does it contest that wind turbines are known to kill birds. Why therefore
has SNH not objected to the project, firmly and unequivocally?
SNH goes even 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 at previous link above.
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, statements in the new impact assessment based on virtual reality contradict established fact - i.e.
the recorded flights as shown on the map referred to previously.
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
the site chosen by the promoter to erect his turbines is paradoxically:
- 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 again.
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 or
- its use by the consultant is faulty; or 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
the other half of their flying time there. This distortion of reality has allowed the Inverliever promoter to declare the
wind farm site as being unimportant for 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 an excellent case in point.
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 endorse the Inverliever
project by its lack of objection.
In addition, 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.
It should not be forgotten
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 Eagle may settle in the Loch Awe area.
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