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Complaints to the European Commission - biodiversity - VERY URGENT

mark duchamp 09 May 2007 05:36
To: Georges.Kremlis@cec.eu.int


Dear Sir,


I wish to submit five complaints ( below ) in relation with the reckless manner in which Scottish authorities are granting approvals to windfarm applications in eagle-sensitive areas. The results will be felt on European biodiversity.

I beg of the European Commission to demand that the Wild Birds and Habitats Directives ( 79/409/EEC and 92/43/EEC ) be enforced in Scotland.

There is utmost urgency in this matter, as bulldozers may start their destruction any time now. The consequences will be the extinction of two species of eagles in the UK, and the loss of one of Europe´s greatest wildlife areas : the Hebrides islands.



Sincerely

Mark Duchamp
Formerly: Windfarms & Birds Research Manager, Proact International
save.the.eagles@gmail.com



COMPLAINT TO THE EUROPEAN COMMISSION



1 - Denouncing flaws in bird collision models, which reduce windfarm mortality predictions by an order of magnitude (1,000%).

2 - Denouncing violations of the Wild Birds and Habitats Directives by the Scottish authorities.

3 - Denouncing the approval of several particularly harmful windfarm projects in the Hebrides islands.

4 - Denouncing the foreseeable extinction of the golden eagle in Scotland ( and the UK ).

5 - Denouncing the foreseeable extinction of the white-tailed eagle in Scotland ( and the UK ).

6 - Conclusion.


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1 - Denouncing flaws in bird collision models, which reduce windfarm mortality predictions by an order of magnitude (1,000%).


I shall use, as an example, the prediction of golden eagle mortality at the recently approved Edinbane windfarm project, Isle of Skye, Scotland.



A ) The Edinbane consultant predicts a precise number of collisions over 25 years, down to the unit, with no margin of uncertainty.

a) - This is un-scientific by definition. Predictions of this nature normally come with a margin of error.

b) - Predicting an exact number of collisions over 25 years violates the precautionary principle.


B ) The consultant predicts that the reduced number of turbines ( 19, down from 27 ) will cause a mortality of 0.6 eagles per annum during the life of the wind farm ( i.e. 15 eagles in 25 years ).

Among the data input to the computer in order to calculate this prediction, we find those flights said to have occurred between 20 and 100 m above ground level in the windfarm area. All others flights have been discarded. But :

a) - there is a substantial probability of error in estimating flight heights, particularly as observations are made from hundreds of meters away. They cannot be made from closer, as human presence would scare the eagles away ( some of that may have occurred as well, with an impact on the results which would favour the developer ).

b) - there is no construction on the hill where the wind turbines are to be erected, therefore no yardstick that would help estimate the flight height correctly.

c) - too many eagle flights recorded in the danger zone between 20 and 100 metres would be a problem for the developer. Ornithologists conducting the survey know it. They also know it is in their best interest to please their employer. The conflict of interest is evident. As a result, zeal may be absent from the surveyors´minds : it is one of these assignments where one is rewarded for working less.

d) - How many flights are missed due to the limited number of hours per day for which surveyors are contracted ? and how many due to distractions during watching hours ? During the course of a day, it is simply impossible to keep looking at the sky, 360º, during 12 hours non-stop.

At Largie, Kintyre, 24 h radar monitoring of geese has shown that :

i) - some flights in low visibility conditions are missed by human observation.

ii) - many flights occur at night. ( Footnote # 4 ).


Eagles too fly in low visibility conditions, or at night, but collision models do not recognise the fact. Says the RSPB ( Royal Society for the Protection of Birds ):



"Studies of radio-tracked golden eagles in Argyll showed that birds frequently flew during heavy rain, in thick mist and when it was so dark that fieldworkers needed torches to get down off the hill" (J Grant personal comment). RSPB objection Eisgein 2006, section 4.2.4



None of the above factors are input to collision models. They would increase mortality prediction if they did.





C ) To obtain the desired prediction of 0.6 per annum, which is the maximum allowed by SNH (5), the consultant makes a controversial assumption :


a) golden eagles are supposed to avoid the turbines 98% of the time, flying around or climbing above them.

This avoidance factor is unrealistic, and favours the developer. It was calculated by SNH from controversial studies ( SNH = Scottish Natural Heritage, an agency of the Scottish Executive ). In real life, eagle mortality at wind farms has been much higher than predicted : by one order of magnitude - i.e. 1,000% ( in Tasmania, for example), and by much more where eagles were thought to be safe : www.iberica2000.org/Es/Articulo.asp?Id=3071

Ornithologists Mike Madders and D. Philip Whitfield, whose works are used as support for erecting more windfarms on eagle territories (1) (2), nevertheless admit that the avoidance factor is "poorly understood", and that predictions by modelling have serious deficiencies:

"There are practical problems associated with gathering the data required to run the model and numerous assumptions must be made concerning bird behaviour. This can lead to deficiencies in the input parameters which potentially have a large effect on the model outputs. Hence, we make recommendations for potential improvements, such as quantifying error in flight height estimation, training of observers in acuity skills, quantifying bird detection-distance functions, and research on factors influencing activity budgets and flight behaviour. In addition, the model outputs are usually adjusted to take account of turbine avoidance by birds and this aspect of birds´ behaviour is poorly understood." - UPLAND RAPTORS AND THE ASSESSMENT OF WIND FARM IMPACTS Mike Madders & D. Philip Whitfield (March 2006)

In such circumstances, the precautionary principle should apply, and a lower avoidance rate should be selected.



In fact, it has been recommended within SNH that 95% be used (6). But it would have yielded a prediction of 5.5 dead eagles a year, i.e. 137.5 over 25 years ( 900% more than with 98% avoidance) (7). This would have been incompatible with the survival of golden eagles on the isle of Skye, let alone the Cuillins golden eagle SPA nearby. So 98% was chosen, allegedly based on a new study. But one hundred per cent of windfarm-related studies nowadays are financed by pro-windfarm money, be it private or public – hardly a guarantee of impartiality.



Suspicions run high that politics were the determining factor in the choice of the 98% avoidance rate, not science. The developer, AMEC, is a company with many friends in Scottish political circles, and with the isle of Skye newspaper : The West Highland Free Press.







b ) – 98% avoidance means that, for 2% of their flights within the windfarm area, the eagles will actually fly through the rotor-swept area. But it is postulated that their speed will be on average 13 m/s ( 47 kph ).


i) - This is unrealistic. Eagles do not behave like inanimate objects, like stones that would be thrown at the turbine. Not considered are the effects of hesitation, circling, surfing the wind to the point of remaining still, and other eagle flight behaviours that would considerably slow the speed of crossing, thus causing more collisions.



As 47 kph is an average speed, all the slower crossings must be balanced by higher speed crossings. Thus, a crossing at 5 kph would have to be balanced by one at 89 kph, or by two at 68 kph, in order to produce an average of 47 kph. But crossings at these higher speeds are not backed by observation. They respond to guesswork. In the real world, it is doubtful that eagles would fly through an obstacle such as a wind turbine at such speeds, taking a deliberate risk : they do possess an instinct for survival.



It is indeed likely that most of the crossings occur at very low speeds, by accident so to speak. Philip Whitfield is in agreement with this when he says, in a "report providing the basis for an SNH response" :



"It seems more likely that in most situations birds like eagles are well aware of spinning blades… but collide when conditions such as winds make it difficult for birds to control their flight and avoid contact. For example, griffon vultures seem to collide in S Spain, not when foraging but when unsuccessfully trying to use winds to climb over turbines (Barrios & Rodríguez, 2004), and at Altamont there are strong associations between topographic features (and therefore wind conditions) and fatality (Hoover, 2002; Smallwood &Thelander, 2004)." (3)



It would seem that SNH chose to ignore this pertinent comment from their expert, a comment that is confirmed by frequent raptor casualties at windfarms across the world* – more frequent than would imply a 98% avoidance rate and an average crossing speed of 47 kph .

* www.iberica2000.org/Es/Articulo.asp?Id=1875






c ) – It is assumed the birds always fly through the rotor at a right angle.



There is no basis for this assumption, which also has the effect of minimising the collision prediction : at any other angle, the exposure to danger would be longer.







d ) – It is assumed the birds fly through the blade-swept-area haphazardly, at any moment in time. Not considered is the timing of their decision to cross or not to cross, in those cases where they are not just pushed by the wind into the rotors.



Unlike objects, birds make decisions. Logically, if the crossing appears dangerous, e.g. if a turbine blade happens to "swoosh" in front of their eyes as they are about to cross, chances are they will turn away. But they may cross if, when they happen to look that way, they only see a wide opening. Thus, it is more likely that they will decide to cross just before the next blade is about to strike ( worst timing, highest risk ), than when the preceding blade has just passed ( best timing, lowest risk ).



This crucial factor is not taken into account by collision models, further distorting predictions in favour of developers.



The distortion, including that caused by other factors mentioned above, may be as high as one order of magnitude (1,000%), as shown by real life mortality. In Norway, for instance, a single windfarm of about 50 turbines is killing white-tailed eagles at the rate of one a month – that´s 300 over 25 years - but the islands eagles will be wiped-out long before that. This, of course, had not been predicted. In Tasmania, another windfarm of about the same size is killing approximately one Tasmanian-wedge-tailed eagle per month ( not for long, because it is a critically-endangered species, and soon there won´t be enough left to be killed at that rate ). The consultant had predicted a mortality of one a year ( twelve times less ). And in California, 2,300 golden eagles were killed in the past 20 years by the very large Altamont Pass windfarm. ( 16 )







e ) – It is also assumed the eagles to be killed at Edinbane ( and Ben Aketil, an adjoining windfarm project ) are to be considered in isolation from other eagles to be killed by other ill-sited windfarms, such as Pentland Road and North Lewis in the Lewis peatlands SPA, Eishken (aka Eisgein) in IBA UK224, Pairc, and dozens more on GE breeding ranges across Scotland ( out of a total of 500 projects).



The cumulative impact of these wind farms on the conservatively-unhealthy UK golden eagle population is likely to be severe. The Edinbane project, located as it is in a busy dispersion area for golden and white-tailed sea eagles, will act as a population sink for roaming young eagles of both species . Even considered alone, it will send the GE population into decline ( see chapter 4 below : Denouncing the foreseeable extinction of golden eagles in Scotland… ).





The effect will also be severe on the white-tailed sea eagle population, which only numbers 33 pairs, over 90% of them established in the Hebrides islands. Edinbane, Ben Aketil, Pentland Road, North Lewis, Eishken, Pairc, and a dozen more projects are targeting these islands.











2 - Denouncing violations of the Wild Birds and Habitats Directives by the Scottish authorities.





EU Wild Birds and Habitats Directives ( 79/409/EEC and 92/43/EEC ) are being violated in a number of ways. Examples of the techniques employed are outlined in detail here :

http://www.iberica2000.org/Es/Articulo.asp?Id=3426



This paper, published as it is on Internet, is intended for a wide audience, hence the language used. Please do not draw your conclusions based on its format : just consider the facts, which are documented. If you need more documentation, please ask me at : save.the.eagles@gmail.com



Article 4.4 of the Wild Birds Directive states :



" 4. In respect of the protection areas referred to in paragraphs 1 and 2 above, Member States shall take appropriate steps to avoid pollution or deterioration of habitats or any disturbances affecting the birds, in so far as these would be significant having regard to the objectives of this Article."



In the Hebrides, at least one IBA and one SPA are being targeted by windfarm developers ( see chapter 3 below). Besides, the broader objective of the Wild Birds and Habitat Directives´ is to protect vulnerable species throughout their range. In this regard, the windfarm projects of Edinbane and Ben Aketil will cause significant harm to 2 protected eagle species ( see next chapter ).



Cumulatively, the extinction in the UK of 2 eagle species may occur ( see chapters 4 and 5 ). And this would be yet another violation of the Directives.









3 - Denouncing the approval of several particularly harmful wind farm projects in the Hebrides islands.



The Hebrides islands, in Western Scotland, are the last stronghold for UK eagles. They hold about 90% of the rare white-tailed sea eagle population, and produce a surplus of golden eagles that fly to the mainland and help maintain the species against attrition caused by human persecution ( 8 ).



Without this immigration from the Hebrides, the eagle population in the rest of the UK would plummet.



But this essential stronghold is under threat ; several windfarm projects are targeting the Hebrides :



A) - Edinbane, isle of Skye, predicted by the developer to kill 15 golden eagles and up to 2 white-tailed sea eagles over 25 years. ( 17 )

In real life, about 150 golden eagles and 20 white-tailed eagles are likely to be killed in that period ( as shown above : 1 - Denouncing flaws in bird collision models, which reduce mortality predictions by an order of magnitude (1,000%) ).



Note : out of 716 known and potential golden eagle territories in Scotland, only 443 are occupied by a breeding pair ( 14 ). Apart from Scotland, there is just one pair in England, and reintroduction is being attempted in Ireland.



The UK has also 33 breeding pairs of white-tailed sea eagle, all of them in Scotland.



Status of the project : approved, with the Scottish Executive expected to give the green light to bulldozing the site any time now ( valuable peat will be destroyed, releasing C02 into the atmosphere as it dries out ).





B) - Ben Aketil, isle of Skye, predicted by the developer to kill 3 golden eagles and no white-tailed eagle over 25 years. In real life, over 30 golden eagles and a number of white-tailed eagles are likely to be killed in that period ( as shown above : 1 - Denouncing flaws in bird collision models, which reduce mortality predictions by an order of magnitude (1,000%) ).

An independent analyst, Dr. Jeremy Carter, applied the method developed by Dr. Smallwood and Karl Thelander to estimate eagle mortality. He wrote :

"1.14 The 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 (13). Leaving aside the fact that the applicant´s assessment is very likely an underestimate of the collision risk for Golden Eagle (as I have shown), it implies that even the applicants 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". (9)



The context : it is estimated that the 30 GE pairs breeding on Skye fledge yearly an average of 17.5 young ( including those from the Cuillins SPA ) (10). The Edinbane and Ben Aketil hills are the focal points of an eagle "dispersion area" on the island. There, young eagles from both species come to hunt, soar and interact. On the Edinbane hill alone, 55 flights of golden eagles and 12 flights of white-tailed sea eagles were recorded by the developer´s consultant in just 60 hours of observation ( 12 ). This is about one GE flight per hour.



Given the local fledging rate of 17.5 GE yearly, and the propensity of young GE to fly over Edinbane and Ben Aketil, Dr. Carter´s figure of 9.3 GE collisions per annum for Edinbane/Ben Aketil is not unrealistic.



He could not perform the same calculations regarding white-tailed eagle collisions, because of the absence of studies that would permit it. But extrapolating from the inter-specific frequency of flights on the Edinbane hill, one may reasonably assume it would be, very roughly, one fifth of the calculated GE collisions, i.e. about 1.8 WTE collisions a year for Edinbane/Ben Aketil, or 45 collisions over 25 years .



These mortality factors, in addition to those of other Hebridean windfarms and related power lines, would affect the sustainability of the following protected areas in the Hebrides : Cuillins SPA, Rum SPA, Lewis SPA, North Harris SPA, Eishken IBA. For it should be remembered that young eagles coming to hunt, soar and interact over Edinbane and Ben Aketil are not limited to those from the Cuillins SPA and the rest of Skye. Young eagles from other SPA and IBA on the Hebridean islands, and even from the mainland, are likely to fly one day or another over those hills. For it is the destiny of young eagles to roam during 4 years or more over whole countries before settling down to breed.



Windfarms on the Edinbane and Ben Aketil hills will act as ecological traps for these roaming birds.



Status of the project : the green light is on - bulldozers expected to start any day ( more peat to be destroyed… ).





C) - The Muaitheabhal windfarm project on the Eishken estate (aka Eisgein, or Eisgen ), also located in the Hebrides ( isle of Lewis ).



If approved, the project would violate the Scottish Natural Heritage guidelines, the RSPB guidelines, the Bern Convention, and the EU Wild Birds and Habitats Directives, all of which stress the necessity of protecting listed bird species as well as the habitats that are necessary for their survival.



The proposed wind farm is to be erected within an Important Bird Area ( IBA UK224 ) that is home to about 10% of the UK population of white-tailed sea eagles, and to 11 breeding pairs of golden eagles. It is also habitat to 8 additional Annex I species protected under both EU and UK laws, plus 2 species protected under UK legislation alone.



This IBA constitutes one of the finest eagle habitats in the UK, perfectly suited for the recuperation of the white-tailed eagle species. As such, it should have been designated a Special Protection Area in accordance with EU Wild Birds and Habitats Directives ( none have been designated in the UK for the WTE ). Failing which, the more stringent requirements of Article 4.4 of the Birds Directive should apply :



" 4. In respect of the protection areas referred to in paragraphs 1 and 2 above, Member States shall take appropriate steps to avoid pollution or deterioration of habitats or any disturbances affecting the birds, in so far as these would be significant having regard to the objectives of this Article." - The European Court of Justice has shown that these words are not to be taken lightly.



The project will kill eagles of both species, as admitted by the consultant. But his prediction is, as expected, grossly underestimated. For details, see :

www.iberica2000.org/documents/EOLICA/LEWIS/EISHKEN_EAGLE_KILLER.doc



The initial project was rejected, so the developer presented a new application for a smaller windfarm of 50+ turbines. See my comments on this manoeuvre, here :

14 - THE DOWNSIZING ILLUSION

http://www.iberica2000.org/Es/Articulo.asp?Id=3426



Status of the project : to be approved at any moment. This site is also covered in valuable peat, a carbon sink.







D) - Pairc, next to Eishken.



The project is soon to be applied for. The area is home to some golden eagles, and possibly to white-tailed as well. No more is known for the time being.







E) - Pentland Road, on Lewis. This windfarm project is located, not only within the Lewis peatlands SPA, but also within the breeding range of a pair of golden eagles. Complete details on this violation of the European Directives are available here :

http://www.iberica2000.org/documents/EOLICA/LEWIS/Objection_Pentland_Road_Windfarm.doc



Status of the project : approved. All that is needed is the removal of objections by the civil aviation and NATO authorities ( there is an airport nearby ). More peat to be destroyed…





F) - North Lewis . The RSPB are campaigning against this massive windpower project that will lie within the Lewis peatlands SPA - 234 turbines, now downsized to 181. They announced that they would send a complaint to the European Commission. But they may have failed to do so ( see chapter 6 ( Conclusion ) below, on the conflict of interest within the RSPB ).



Here is my objection to this highly destructive project :

www.iberica2000.org/Es/Articulo.asp?Id=2030



Status of the project : approved, in spite of objections lodged by 11,000 islanders. Great quantities of peat to be destroyed – see RSPB objection.





G) - North Harris , on Lewis. The John Muir Trust have approved a community project of three wind turbines on wild land administered by them.



Little is known about this project, except that it lies at the edge of the North Harris SPA and within 800 meters of a nest of golden eagles.



Small windfarms are not harmless to birds. In Sweden, a wedge-tailed eagle was killed by a group of 3 wind turbines (13 ). At Cordelia, California, a solitary turbine is estimated to have killed 54 birds in one year ( 13 ).



Status of the project : unknown.





H) - More projects in the rest of the Hebrides islands.



There are a number of them, but I haven´t had the time to research. In any event, the importance of the Hebrides as a haven for European wildlife, and eagles in particular, demand that they be kept free of machines that are known to have killed at least 2,500 eagles and millions of other birds worldwide. ( 13 )



Kilometres of new power lines would also be allowed to criss-cross many unspoilt areas, killing more protected birds.



Status of the projects : unknown.







As I said before, the Hebrides islands are the last healthy eagle-haven in the UK. They hold 90% of its WTE population, and produce a surplus of golden eagles that helps maintain their failing population on the mainland.



Installing windfarms on these islands is a crime against European biodiversity.











4 - Denouncing the foreseeable extinction of the golden eagle in Scotland ( and the UK ).





In the world, c.2,400 golden eagles have been killed by windfarms already, that we know of (16). Obviously these birds are not being scared, "displaced" by the turbines as SNH would like us to believe. On the contrary, Thelander and Smallwood have observed that they seem to be attracted by them (18). From the numerous kills, and from these observations by reputed ornithologists, we may safely assume that the large raptors are likely to get killed whenever wind turbines are erected in their habitat.



At the last Scottish GE census (2003), 443 out of 716 known and potential eagle territories were occupied by pairs (8). This population failed the tests determining satisfactory conservation status as defined by the European Habitats and Species Directive (92/43/EEC). It is in demographic difficulty, a condition that will lead, all things remaining equal, to population decline.



Any additional mortality will cause the decline to occur sooner, and to be more severe thereafter. This may be ascertained from existing scientific studies; the subject is covered in detail here : ( 14 ).



And precisely, additional mortality is what the windfarms will bring about, on a large scale, across Scotland ; particularly those planned for the GE stronghold in the Hebrides islands ( chapter 3 above ). In biological terms, it will be "additive mortality" ( as opposed to "compensatory mortality" ), because the species is already in demographic difficulty.



One imaginative ornithologist, in his zeal to defend the most ill-sited of windfarms, wrote to the Raptor_Conservation Forum : ( I quote from memory ) nothing proves that the eagles dying from collision with the rotors would not have died from other un-natural causes. He was trying to dismiss my argument about windfarm mortality in Scotland being additive. But logic offers a counterpoint : nothing proves the rotor victims would not have died of old age either. And in any event, the precautionary principle should apply.



Strange argument indeed, coming from a professional supposed to be defending the birds. It shows to what extremes some ornithologists push their rhetoric in order to please windfarm developers, and hopefully get a job from them unless they have it already.



The approval of the Hebrides windfarms, already obtained for some, and soon-to-be-obtained for others*, violates the EU Wild Birds and Habitats Directives on an individual basis. But if we consider these projects cumulatively, there is an additional violation inasmuch as the very survival of a protected species is at stake.



* see chapter 3 above. In any case, by the time this complaint is considered, most of them will have been approved.



It will be argued that those eagles that have their breeding ranges more than 6 km away from the nearest wind turbine will not be affected. But what of their young, whose destiny it is to be roaming over the whole country for years before settling down ? We must realise that Scotland will be covered in wind turbines : 5,000 or more, spread across the country, often on hilltops where eagles fly. Mortality among immature eagles will be very high. Of the c.2,300 GE killed by the huge Altamont Pass windfarm in California, over 90% were sub-adults – the "farm" is effectively acting as a population sink for future GE generations *.



Sooner or later, in Scotland, there will be no young eagles to replace whichever adults have been spared, when these die of old age.



To save the Scottish ( and UK ) golden eagles from extinction, it is imperative that the Hebrides be declared turbine-free.



* Note : to those who still argue that mortality at Altamont is exceptional because of the lattice-type structures of the old wind-turbines, I oppose the studies by Dr. Smallwood & Thelander that prove this wrong : modern turbines and other

locations are no less lethal. See footnote below : ( 19 ), which also refers to the

Altamont mortality : 116.5 GE p.a. x 20 years = 2,330.







5 - Denouncing the foreseeable extinction of the white-tailed eagle in Scotland ( and the UK ).







The WTE, it may be argued, is in expansion and has a breeding success rate comprised between one and two fledglings a year ( as opposed to about 0.50 for the Scottish GE for instance). But the species is extremely vulnerable in the UK for the following reasons :



- It only numbers 33 breeding pairs.



- No SPA has been designated to protect it.



- About 90% of its population is in the Hebrides, where many wind turbines are to be erected in the areas where they fly.



- The 10% or so living on the mainland are not exempt from risk, as there are 500 windfarm projects in Scotland, thousands of kilometres of power lines, and more persecution than on the islands.





WTE´s are being killed by the Smola windfarm in Norway at the rate of one per month. Mortality in Germany is also significant : in spite of there being no systematic and scientific monitoring, finds of dead WTE´s under wind turbines numbered 17 as at January 11th 2006. And more have been killed by the giant rotors in Sweden and in Japan. More details here : www.iberica2000.org/Es/Articulo.asp?Id=3071





Not all kills are registered with the authorities ; not all that are registered are made public ; and not all that are made public are known to me. So the mortality shown above is obviously the tip of the iceberg.



Prone to be killed by wind turbines, and numbering only 33 breeding pairs concentrated in the Hebrides, there is little doubt that few WTE will be able to survive when their island habitat is sprinkled with hundreds of these ecological traps. Those adults that will be lucky enough to breed at a safe distance from wind turbines will have their young destroyed as these roam about the islands. So they may be without successors when they die of old age. We are facing yet another probable extinction in the UK.







6 - Conclusion





When it comes to wind farms, Scottish political authorities are not respecting the EU Wild Birds and Habitats Directives.



If Scotland is to continue sustaining any eagle population at all, the European authorities must take rapid and decisive action to stop the construction of the most damaging of the 500 windfarm projects : those located in the Hebrides. These islands must remain turbine-free.



The lives of many other Annex I species are also at stake, but I have neither the time nor the resources to evaluate the cumulative effects of 5,000+ turbines on these. I only know that raptors such as hen harriers, merlins, peregrine falcons, ospreys, and the recently-reintroduced red kite will be notably at risk.



Windfarm interests have become the Nº1 employer of ornithologists in the world, spending many millions for avian impact assessments and other bird studies that whitewashes their industry. It alters considerably the judgment and/or the morals of these bird experts. Hence their attacks against me. One of them, who holds a position of responsibility in Scotland, says that my claims are "wild and unsubstantiated".



Not surprisingly, he keeps saying that but never refutes my arguments. He would be hard-put to do it, as they are substantiated by their own studies. For if their summaries and abstracts, if their "discussions" and conclusions are biased in favour of the windpower industry, the body of their reports yields important evidence to anyone who cares to read them through and through.



The extinction of a species, when predicted decades in advance, may appear to be a "wild claim" to those who prefer to look the other way because they have a personal interest in windfarms. It is an easy job for them being sceptical, because proof can only be brought forward when the species is, indeed, extinct. It is too late then.



There is yet another conflict of interest that affects the judgment of ornithologists when it comes to the possible extinction of a bird species. It stems from the money that will be spent by the government in order to save it. And if a bird species has been completely "extirpated" from any given country, then money will be spent to reintroduce it. Some ornithologists will earn a living that way ; many more are hoping they might.



Thus, today, ornithologists find jobs at windfarms that kill or will kill protected birds; and they will find jobs tomorrow to reintroduce the species that have been driven to extinction by these windfarms. For them, it is a win-win situation. This, better than anything else, explains their staunch support for windpower - even if it affects bird reserves such as SPA´s, IBA´s, Ramsar and Natura 2000 areas.





This is, of course, immoral. And from a conservation point of view, species should not be allowed to reach extinction levels, for it means that their habitat will have been destroyed.





The windfarm industry is also a major contributor to the wealth of bird societies and other trusts and charities. A case in point : SEO-Birdlife, in Spain, is partly financed by donations from Iberdrola and Triodos Bank. And another : in the UK, a renewable energy product called "RSPB Energy" is being sold by Scottish & Southern Energy - and the RSPB receives money for lending its name. In the US, the Peregrine Fund enjoys a relationship with the wind industry. This picture is more eloquent than a long speech:

www.iberica2000.org/documents/EOLICA/$100,000_Peregrine_Fund.jpg





The RSPB, who finally decided to oppose the North Lewis project with some conviction ( because of the critiques received ), are otherwise supporting the drive to cover Scotland ( and Wales ) in windfarms. Witness their support of the recent application for a large-scale windfarm in the Shetlands ( 160 turbines ) in spite of these islands being a staging post for migrating birds to and from the Arctic. And the local weather will make things worse : plenty of rain, fog, and high winds - i.e. poor visibility and poor manoeuvrability for the birds.



It is important to judge ornithologists and RSPB management by their acts, not by what they are, or what they say. Important because you may be tempted to think : if the eagles were at risk, Scottish ornithologists and the RSPB would complain.



But in reality they won´t complain, because of the strong conflicts of interest I have mentioned. The RSPB protest against the North Lewis project ( aka Lewis Wind ) is the exception that confirms the rule.



Now you may realise that there is reason for concern : the traditional birds´ advocates are not defending the birds against windfarm interests. Who does, then?



I am retired, and have a deep concern for the preservation of nature : it is the best legacy to be passed on to our children. - I do not receive any money for my work.



I have spent 5 years researching the subject of windfarms and birds, particularly in Scotland as evidenced by the following paper : http://www.iberica2000.org/Es/Articulo.asp?Id=3426



My work is known by many ornithologists worldwide, by SNH, by the RSPB, and by various continental Birdlife organizations. The Fish & Wildlife Service of the United States acknowledges having used it ( 15 ).



For the sake of European biodiversity, I hope that you will uphold my complaint, and take rapid action to save what may still be saved from the windfarm onslaught. The Hebrides seem to be the best choice for such a rescue operation : they are essential to the survival of eagles in the UK, and provide a haven to many other Annex I bird species.



Spain´s Extremadura is another : there are 116 windfarm projects for that region, regardless of its claim to be Europe´s treasure chest in terms of biodiversity : cranes, great bustards, imperial eagles, bonelli´s eagles, golden eagles, booted eagles, short-toed eagles, black storks, white storks, black vultures, griffon vultures, hen harriers, peregrines, lesser kestrels, black-shouldered kites, eagle-owls, etc. are a few of its jewels. The rest of Spain is no longer safe for these magnificent creatures, with 12,000 deadly rotors standing in their way.



Soon, the Hebrides in Scotland, and Extremadura in Spain, will be turned into killing fields for European wildlife. Urgent action from the EU is needed to stop that crime from happening.









Mark Duchamp
Formerly: Windfarms & Birds Research Manager, Proact International
save.the.eagles@gmail.com


PS : the following papers have subsequently been sent to the European Commission as additional information :

RSPB executives are causing severe harm to bird life

Windfarms to wipe out Scottish eagles



FOOTNOTES :

(1) - RESIDENT GOLDEN EAGLE RANGING BEHAVIOUR BEFORE AND AFTER CONSTRUCTION OF A WINDFARM IN ARGYLL, 2005, D Walker, M McGrady, A McCluskie, M Madders & D R A McLeod.

This study fails to stress the significant negative impacts of the windfarm : see section 2 on Beinn an Tuirc,
chapter : THE EFFECT OF WINDFARMS ON THE SCOTTISH GE POPULATION www.iberica2000.org/documents/EOLICA/LEWIS/OBJECTION_LEWIS_EAGLES_2007.doc





(2) - SPATIAL ASSOCIATION AS AN INDICATOR OF THE POTENTIAL FOR FUTURE INTERACTIONS BETWEEN WIND ENERGY DEVELOPMENTS AND GOLDEN EAGLES AQUILA CHRYSAETOS IN SCOTLAND", by Alan H. Fielding, D. Philip Whitfield and David R.A. McLeod (2006).

This study misrepresents the size of golden eagle territories, in favour of windfarm developers. See : www.iberica2000.org/Es/Articulo.asp?Id=3426
chapter 1 : REASONING LIKE POACHERS

(3) - EDINBANE WIND FARM EAGLE ACTIVITY ASSESSMENT V3, October 2004, by E.S. Lawrence - Comments by Phil Whitfield with input from Bill Band - 26 November 2004 : "1. This report provides the basis for a SNH response to the above report by E.S. Lawrence of LEC."





(4) - BIRD DETECTION RADAR AS A TOOL FOR MONITORING

WHITE-FRONTED GOOSE, ANSER ALBIFRONS FLAVIROSTRIS

MOVEMENTS AROUND THE PROPOSED LARGIE WIND

FARM, KINTYRE - Walls, R.J., Brown, M.B., Budgey, R. & Parnell, M. (2005)

Commissioned by EcoGen Projects Ltd / Eurus Energy UK Ltd.





(5) - LETTER of December 14, 2004 from James King to Major R. Hilleary - available upon request.



(6) - A LETTER dated 23rd August 2004 from ornithologist and eagle specialist Jeff Watson to John Rennilson, Director of Planning Highland Council, states as follows:

"As discussed in our meeting we recommend that the priority is for AMEC to reanalyse the existing data to reassess collision risks both overall and at individual turbine level. This exercise should be done in liaison with Phil Whitfield and should use a 95% avoidance rate".

October 2004 - Stephen Lawrences Edinbane Eagle Activity assessments states :

"As a precautionary stance SNH advises that the calculation should be undertaken with a 95% avoidance rate."

(7) - In May 2004 Alex Turner SNH´s area officer for Skye and Lochalsh advised the late John Greaves of Highland Council:

"If the recommended avoidance rate of 95% is applied then 5.5 eagles per year are predicted to be killed at Edinbane".





(8) - "A CONSERVATION FRAMEWORK FOR THE GOLDEN EAGLE IN SCOTLAND - REFINING CONDITION TARGETS AND ASSESSMENT OF CONSTRAINT INFLUENCES", by Philip Whitfield, Alan H.Fielding, David R.A. McLeod, Paul F. Haworth and Jeff Watson (2006).

Published: Biological Conservation, 130 (2006) 465-480





(9) - "THESE REPRESENTATIONS SUPPLEMENT AND REINFORCE MY ORIGINAL REPRESENTATIONS OF 29 NOVEMBER and 20 DECEMBER 2002"

by Dr. Jeremy Carter, 23 April 2004
www.iberica2000.org/Documents/EOLICA/EDINBANE/objection_Ben_Aketil_Dr_ Carter.pdf





(10) - "…about 17.5 fledglings per year are produced (roughly 30 pairs with 0.58 fledging rate)" - Edinbane Wind Farm Eagle Activity Assessment v3, by E.S. Lawrence - Comments by Phil Whitfield with input from Bill Band - Nov. 2004
www.iberica2000.org/Documents/EOLICA/EDINBANE/Edinbane_Eagle_Assessment.doc



(11) - Eagle Studies - Predicted Collisions at Edinbane Jan-July – Document presented in 2006 by the wind farm developer AMEC.
www.iberica2000.org/Documents/EOLICA/EDINBANE/Predicted_Collisions.pdf




( 12 ) - Edinbane Confidential Annex – June 2002 - AMEC
www.iberica2000.org/Documents/EOLICA/EDINBANE/Edinbane_Confidential_Annex.pdf





(13) - www.iberica2000.org/Es/Articulo.asp?Id=1875





(14) - OBJECTION TO THE REVISED APPLICATION FOR A LARGE WINDFARM OF 181 TURBINES IN THE LEWIS PEATLANDS SPA AND RAMSAR WETLAND – PART 2. Mark Duchamp, Feb. 4th, 2007.

www.iberica2000.org/Documents/EOLICA/LEWIS/OBJECTION_LEWIS_EAGLES_2007.doc





(15) - US FISH & WILDLIFE SERVICE LETTERS : available upon request ( weight : 2.4 Mb and 12.8 Mb, respectively ).





(16) - www.iberica2000.org/Es/Articulo.asp?Id=3071





( 17 ) - Edinbane Revised Proposal : www.iberica2000.org/Documents/EOLICA/EDINBANE/Edinbane_Revised_Proposal.pdf



paragraphs 17 and 20.





( 18 ) - "raptors spent significantly more time flying at close proximity to turbine blades ... than 51-100 m away ... or >100 m away … Analyzing the total number of minutes of flight time reveals that something about wind turbines may attract red-tailed hawks to fly near turbines and at dangerous heights. Similarly, American kestrels flew in proximity level 1 [ie 1-50m from turbine] nearly four times longer than expected by chance, golden eagles two times longer, and northern harriers three times longer"

BIRD RISK BEHAVIORS AND FATALITIES AT THE ALTAMONT PASS WIND RESOURCE AREA, Thelander, C. G, Smallwood, K.S., Rugge, L. - Period of Performance: March 1998-December 2000, National Renewable Energy Laboratory Report SR-500-33829, 2003. www.nrel.gov/docs/fy04osti/33829.pdf



( 19 ) - Thelander, C. G, Smallwood, K.S., Rugge, L. ( 2003 ) : "It appears that factors other than tower type play more of a role in whether a particular turbine is associated with one or more fatalities, such as prey distribution about the tower´s base, physical relief, and presence of declivity winds. Regardless, the number of fatalities at tubular towers was higher than at horizontal lattice towers" - (18 ) above, Chapter 6: Discussion.



In another report, we find the following :



"Adjusting for local relative abundance, the existing data indicate that most wind energy generating facilities have an equal impact on the local raptors." Chapter 4 – Paragraph 4.4.1 of : DEVELOPING METHODS TO REDUCE BIRD MORTALITY IN THE ALTAMONT PASS WIND RESOURCE AREA - Dr. Smallwood & K. Thelander (2004). – available online here:

http://www.energy.ca.gov/pier/final_project_reports/500-04-052.html



In this same report we find the figure of 2,300 GE killed over 20 years ( the age of the windfarm ) : CHAPTER 3, TABLE 3.11, 1ST LINE, : "116.5 golden eagles p.a. adjusted for search detection and scavenging." –

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