Mr J D Rennilson
Director of Planning and Development
The Highland Council
Glenurquhart Road
Inverness
IV3 5NX
21 June 2006
Dear Mr Rennilson,
OBJECTION TO THE CONSTRUCTION OF A WINDFARM AT EDINBANE, ISLE OF SKYE – reference 02/00089/FULSL
The Isle of Skye is important to bird life and to Golden and White-tailed
Eagles in particular. The island is a haven for both species, and a successful breeding ground from where young eagles emigrate
to the mainland. It is a population source which benefits other regions of Scotland.
White-Tailed Eagles (WTE - also known as Sea Eagles):
The island played an important role in the reintroduction of the WTE in
Scotland, where 32 pairs are now breeding. Skye and the rest of the Hebrides remain the essential population source of WTE
for the rest of Scotland.
Golden Eagles (GE):
The Hebrides islands, of which Skye is the centrepiece, are essential to the sustainability of the
Scottish GE population. Without young eagle emigration from the Hebrides, the GE population on the mainland would be smaller.
Even with that contribution, it is now about to decline. This is evident in the recent study by Whitfield et al. (2006), which
shows an excessive proportion of sub-adults (10%) among Scottish breeding pairs. It is a sign of demographic difficulty; the
precursor of population decline.
In the same study, Skye is identified as a population source. It states initially: "Despite apparent overall population stability
over the last 20 years, the national golden eagle population failed to meet the
abundance target and only 3 of 16 regions where eagles have occupied territories since 1982 were considered to be in favourable
condition.”
A look at the map shows that the 3 regions found to be in “favourable condition” are basically
the Hebrides’ “eagle islands”: Western Isles, Mull and Skye.
The
report then goes further and identifies Skye as the likely population source
for the mainland region immediately to the east. Referring to the deficient reproduction rate of golden eagles in the region
known as the Western Highlands (NHZ zone 8), it states: “The most likely source of immigrants was the neighbouring
NHZ 6* (Western Seaboard: Fig. 1) where high occupancy has been stable for decades and demography appeared to be sufficiently
favourable.”
* NHZ 6 is composed of Skye + small nearby islands.
In the circumstances, it is obvious that a reduction in the survival rate
of golden eagles on Skye would have a negative impact on the mainland population. Yet, this is precisely what Scottish Natural
Heritage is about to authorise. They have indicated
to the promoter that the killing of 15 golden eagles by the Edinbane windfarm would be acceptable, because it would not harm
the GE population of the Cuillins SPA on the Isle of Skye. But they have overseen the bigger picture; the eagle population
of the Western Highlands (NHZ zone 8) will suffer as a result.
It must also be taken into account that GE emigration from the Western Isles
to the mainland must pass through Skye, which lies between. There is little doubt that some of the young eagles from Lewis,
Harris etc. will be killed at Edinbane, a strategic dispersion location straddling their route to the mainland. The negative effects will be thereby compounded.
All this is bad enough. But many more than 15 eagles will be killed in the
long run:
1) - More windfarms will be built on Skye. In addition to Edinbane, the
next most advanced project is Ben Aketil, also badly sited in the same busy eagle dispersion area. The promoter predicts that
5 golden eagles will be killed here.
2) - These projections span the useful life of the wind turbines - 25 years.
Experience shows however (Altamont Pass, Tarifa, Denmark etc.) that old turbines are usually replaced by new ones. If realistically
projected further into the future, say 100 years (if only to follow the precautionary principle), the killing of 15 + 5 golden
eagles increases to 80.
3) - It is widely accepted that the model in use is inaccurate, and that
results fluctuate widely depending upon the variables introduced. The British Trust for Ornithology, in its “Appraisal
of the SNH Wind farm Collision Risk Model” states: “Predicted mortality increased exponentially at very
low speeds (< 5m/s), but it is doubtful whether many birds fly at this speed.”
While it is true that most birds fly at speeds higher than 5 m/s, this is not applicable to eagles
and other raptors. These birds glide and leisurely soar in circles. Their speed often falls below 5 m/s. In some instances,
eagles use the wind to maintain a stationary position with no forward movement. Yet the promoter’s consultant uses a
standard speed of 13 m/s. This produces unrealistic results which, according to the BTO would in reality be exponentially
higher.
The BTO report singles out several other variables that may have a significant
impact on the results. For instance: “Errors in bird counts and numbers at risk height will translate
into directly proportional errors in predicted mortality rate.” This is extremely pertinent for Edinbane, where
only eagles estimated to be flying between 10 to 100 metres were included in the model.
What about those birds estimated to be flying at 105
metres? What if they were actually flying at 98
metres? Can observers accurately estimate to within one
metre the height at which an eagle is flying?
In addition, the calculations are curious. “Eagle Studies at Edinbane, Aug-Dec. 2005, paragraph
14” states:
“Observations
of birds flying at 10-100m were used in the analyses”
But, in paragraph 9 on GE, it reads: “A total 3.5 of hours was spent flying at 10-100 m elevation and 2.8 hours at 50-150m.”
It appears therefore that a substantial number of flights between 50 and 100 meters were omitted from
the modelling. This is sufficient to invalidate the mortality prediction.
4) - Another important variable is the avoidance factor. SNH has set this
arbitrarily at 98%, whereas in other windfarm applications (Lewis, Eishken) a rate of 95% was used: "Following discussions
with SNH, an avoidance rate of 95% has been used to reflect species thought to be most sensitive to collisions." (ES Lewis Windfarm Proposal Chapter12, Para. 231)
The “sensitive” species in question is the GE. Why does SNH use 95% for eagles on Lewis, but 98% on Skye?
The higher the avoidance rate, the smaller the eagle kill estimate!
The BTO states: “Avoidance rates used in the examples presented
were high (>0.90) and therefore resulted in a large adjustment to predicted mortality. Equally, small errors in avoidance
rate were shown to result in large percentage changes in predicted mortality rates.”
To summarise: the predicted mortality has been calculated arbitrarily, in
order to minimise it. In reality it is likely to be substantially higher. Nevertheless, even the 15 eagle deaths predicted by the Edinbane promoter are unacceptable. This mortality rate would suffice to send
the Scottish GE population as a whole into decline, with no clear outcome.
Besides, Edinbane is just the tip of the iceberg: a total of 400
windfarms are currently in the planning pipeline for Scotland (source: Malcolm Ogilvie,
Scientific Advisory Committee to SNH). It is all the more imperative that the Isle of Skye is allowed to remain a safe haven
for the beleaguered Scottish eagles.
We object to the Edinbane windfarm project for the reasons stated above.
David Conlin
Coordinator Proact International
and the following (864) members of the Proact Team
(names listed)
representing
AFRICA: Cameroon, Ghana, Kenya, Republic of South Africa, Swaziland, Uganda,
Zimbabwe AMERICA NORTH: Canada, USA AMERICA
- CENTRAL and SOUTH: Argentina, Brazil, Costa Rica, Honduras, Mexico, Peru, Uruguay ASIA: Bahrain, Bangladesh, Bhutan, Burma, Hong Kong, India, Indonesia, Japan, Jordan,
Malaysia, Mongolia, Nepal, Philippines, Singapore, South Korea, Sri Lanka, Taiwan, Thailand, United Arab Emirates AUSTRALASIA: Australia, New Zealand EUROPE: Austria,
Belgium, Croatia, Cyprus, Denmark, England, Finland, France, Germany, Ireland, Israel, Italy, Luxembourg, Malta, Nepal, Netherlands,
Norway, Pakistan, Poland, Romania, Russia, Scotland, Serbia & Montenegro, Slovakia, Spain, Sweden, Switzerland, Taiwan,
Turkey, Ukraine, Wales
