An application has been submitted for an industrial wind farm on the North Lewis Peatlands SPA.  We believe the proposal will have a damaging impact on a huge number of important bird populations including golden eagle, black-throated diver, red-throated diver, dunlin, merlin and greenshank. This is a site of International importance, will you write an objection to the Scottish Executive to help us save it?

The RSPB’s Position on Wind Power and Other Renewables

The RSPB views climate change as the most serious long-term threat to wildlife in the UK and globally. If we are to avert serious disruption to natural, social and economic systems we need to act now to limit the use of fossil fuels that release greenhouse gases into the atmosphere. We therefore support the increased use of wind power, as long as wind farms are sited, designed and managed so they do not significantly harm birds or their habitats.

The Development Proposal

The proposal by Amec and British Energy is for a 234 turbine, 702MW wind farm on the Isle of Lewis in the Western Isles of Scotland. The turbines will be 140m high to the tip of the blade and be supported by a large concrete foundation (approximately 22mx22mx1.5m). The application also includes 167km of roads, nine electrical substations, a control building, nine wind monitoring masts, 210 pylons supporting a network of overhead lines, five rock quarries, eight temporary compounds and four concrete batching plants. All this will take roughly three years to build.

Impacts On Birds

The Lewis Peatlands Special Protection Area (SPA) was classified under the European Council Directive on the Conservation of Wild Birds (79/409/EEC); the site encompasses an area of 58,984 hectares. The qualifying species are:

• Red-throated diver         80 pairs                        (9% British breeding population)
• Black-throated diver       13 pairs                        (8% British breeding population)
• Golden eagle                5 pairs              (1% British breeding population)

·         Merlin                          20 pairs                        (1% British breeding population)

• Golden plover                1800 pairs         (8% British breeding population)
• Dunlin                          3400 pairs         (37% British breeding population)
• Greenshank                  140 pairs          (10% British breeding population)

Of all the British SPAs, this has the largest population of golden plover at the highest densities; it also has the largest population of dunlin. It is also almost certainly the ‘best’ site in Europe in terms of golden plover and dunlin.

The developers have attempted to define ‘critical’ areas within the SPA by identifying those areas most frequently used by red-throated divers, black-throat divers, golden eagle and merlin – it is not possible to do so for golden plover and dunlin because they occur in such high densities across the entire survey area.

The Environmental Statement (ES) produced by the developer states that:

·         50 golden eagles; and

·         16 red-throated divers are at risk of colliding with the development throughout its 25-year lifetime.

The ES also concludes that:

·         352 golden plover territories; and

·         314 dunlin territories could be displaced during the operation of the wind farm, hundreds more will be affected during construction.

·         Merlin, greenshank, whooper swans, greylag geese and corncrakes may also be affected by displacement, disturbance or collision.

The ES clearly accepts that for many of the species the level of uncertainty is simply to high too reach any confident conclusions regarding impacts. For example, we know that large numbers of whooper swans regularly migrate over north Lewis and may be at risk of collision. We do not believe that such a high level of anticipated risk combined with such high levels of uncertainty is acceptable in an internationally important site.

Impacts On The Peatland

Peat bogs act as an effective mechanism for fixing and storing carbon or ‘carbon sinks’. The bulk of carbon associated with peat bogs is stored in the organic soil (peat). Construction on peat bogs can cause erosion of the peat and a release of stored carbon. The network of roads, turbine bases, pylons and compounds across the site will lead to direct habitat loss, a disruption to the hydrology of the peatland, erosion and potential peatslides.

The ES concludes that 577hectares of SPA habitat will be lost or disturbed including 152ha of active blanket bog, a priority habitat under the EC Habitats Directive.

The Process

Because this development will affect a European site, the Scottish Executive are required to consider a series of legal tests as set down in Article 6 of the EC Directive on The Conservation of Natural Habitats and Wild Fauna and Flora (EC Directive 92/43/EEC – The Habitats Directive) before consent can be issued. From our analysis above it is clear that we believe the proposal will have a significant and adverse effect on the integrity of the site (Test 1). If the Executive agrees, they must then consider whether there are any alternative solutions to this proposal – including other locations or technologies (Test 2). They must also consider whether there are ‘imperative reasons of overriding public interest’ which justify allowing such a development (Test 3).

We believe that there are many alternatives to this proposal, which would contribute to both the economy of the Western Isles and to Executive renewables targets, without damaging an internationally important site.

An International Context

The success of this application would set a damaging precedent for all internationally important sites. We need to make the Scottish Executive aware that this application is subject to the widest possible scrutiny.

Further information and the Environmental Statement are available on the developers’ website:

http://www.lewiswind.com/es/ES%20Text%20Main.htm

Please Act Now - We need your help

Please read this briefing or have a look at the ES on the web and send an objection to the Scottish Executive before the 13 December 2004.

Objections received after this date may still be considered at the discretion of the Executive.

Please send your objections to:

Lesley Thomson, The Scottish Executive, Consents and Emergency Planning Unit, 2^nd Floor, Meridian Court, 5 Cadogan Street, Glasgow G2 6AT

Email: lesley.thomson@scotland.gsi.gov.uk

For further information, please contact:

Anne McCall

Planning and Development Manager

or Andy Myles

Head of Advocacy & Media RSPB Scotland

25 Ravelston Terrace

Edinburgh EH4 3TP

Tel: 0131 311 6500 Fax: 0131 311 6569

Email: anne.mccall@rspb.org.uk andy.myles@rspb.org.uk

Registered Charity Number: 207076 – August 2003