Abstract
The John Muir Trust is one of the United Kingdom's leading guardians of wild land and wildlife. As a prominent membership organization we carry out our charitable role through the ownership of land, the promotion of education and volunteer conservation activities. In order to protect wild land, the Trust campaigns against threats to wild land and for wild places to be valued by society.
The Trust recognizes the unprecedented threat that we all face from the impact of climate change and the essential role that renewable energy, including wind power, has to play in combating it. The Trust is working to ensure that on-shore wind power is appropriately placed and developed with a minimal impact on vulnerable upland habitats. Uplands contain priority habitats identified by the Convention on Biological Diversity and the EU Habitats Directive, specifically biodiverse grasslands and blanket bog (peatland).
These priority habitats support a diverse community of plant and animal life. They also provide an important element in supplying freshwater to river systems. In addition, they have been identified as important stores of carbon stocks. In effect, the peatlands and biodiverse grasslands are the part of a mosaic of habitats which act as the rainforests of the northern latitudes.
Climate change is likely to impact on uplands by:
- Increased erosion and siltation due to intense storm events;
- Drying out of soils due to changes in precipitation patterns;
- Accelerated decomposition of peaty soils further fuelling climate change, and;
- Increased loss of soil through water and wind erosion.
Given the global importance of peatland and biodiverse grasslands (such as upland heathland), both in terms of biodiversity and as stores of carbon stocks, the EU and Member States have an international responsibility for protecting these habitats from the impact of climate change and development.
Unfortunately, a poorly planned, unsuitably located or inadequately operated renewable energy development and infrastructure could damage and destroy habitats, cause wildlife disturbance and fatalities and, if inappropriately placed, decrease the ability of ecosystems to store carbon stocks.
The John Muir Trust has reviewed various Environmental Statements for wind turbine developments in upland areas. The Trust is concerned to note that wind turbine projects require the removal of considerable areas of upland habitat. This is cleared for turbines, construction areas and infrastructure (such as roads, drainage ditches, buildings, distribution lines, etc.).
Review of development proposals and actual sites indicates that the habitat destruction and land take for a 16 to 53 wind turbine installation is 6.57 to 44.16 hectares. However, the modification of natural drainage by the construction of turbine infrastructure could cause impacts over a much wider area of upland habitat. Modification of peatland drainage by the use of ditch systems associated with wind turbine developments is likely to lead to the drying of peatlands, ultimately resulting in erosion of habitats over a wide area. The size of area is comparable to the land take for the agricultural production of biofuels or construction of an industrial facility (power station, factory, etc.), shopping centre, airport, etc. The habitat damage is also similar to the effects of climate change on upland areas.
The Trust is concerned that:
- Habitats are not being successfully restored after construction;
- Restored habitats do not have the same biodiversity value and carbon storage potential, and;
- Clearance of vegetation, compaction of soils, re-profiling of slopes, etc. result in erosion damage and associated siltation within river catchments similar to predicted climate change impacts.
Research by Stirling University indicates that peatlands impacted by construction lose 25 to 50% of the carbon that would normally be taken up each year "and so adds significantly to the potential impacts of climate change". In addition, independently peer reviewed research by the Royal Society for the Protection of Birds is now also indicating that the impacts of wind turbine developments may not be limited to direct impacts from construction and operation. The research proposes a number of potential causes for lower bird numbers at wind turbine sites. These include avoidance by birds causing displacement of populations to other sites and increased adult bird mortality due to collision with turbines. The research concludes that bird "populations that are under stress from wind farm development are likely to be more susceptible to additional pressures from climate change."
Previous research which could help safeguard our uplands has also been selectively misquoted to suggest wind turbine development on peatlands does not result in significant carbon release, this is particularly with regard to the University of Aberdeen and the Macaulay Institute research report concerning: Calculating Carbon Savings From Wind Farms On Scottish Peat Lands - A New Approach. This report recognised that "Wind farms tend to be sited on peat lands which hold large stocks of poorly protected carbon and so have the potential to greatly increase overall carbon losses." The report developed a formula which needs to be applied to each individual site to calculate losses.
Protection of non-statutory upland sites is being weakened due to inconsistencies in EU Policy and the development, by the Scottish Government, of a "fast track"? planning system which risks paying little attention to protecting habitats outside international or European statutory sites which have stronger legal safeguards due to treaty obligations. The John Muir Trusts believes that unprotected upland areas are now at risk from damage or destruction, resulting in the loss of ecosystems which maintain our wilderness areas, provide habitat for wildlife and act as natural stores of carbon stocks. The EU should reform its renewable energy policy to provide better environmental protection from the construction of wind turbines. The Scottish Government should act now to implement advice it was given in 2006 by the Strategic Environmental Assessment of the Scotland Rural Development Programme to develop a National Renewable Energy Strategy. This paper sets out the problems posed by industrial scale wind turbine developments, together with recommendations on how to safeguard the upland habitats.
Recommendations
European Parliament Given the similar scale and potential environmental impacts renewable energy projects can have on peatlands and biodiverse grasslands, it is recommended that the Directive on the promotion of the use of energy from renewable sources COM(2008) 19 be amended now or by future legislation to ensure that:
- the provisions of the "sustainability regime" enacted by Articles 15, 16 and 17 are extended from the growing of biofuels and bioliquids to also cover the construction and operation of renewable energy generation and distribution projects;
- a similar provision for calculating the greenhouse gas impact of biofuels (Article 17) is also developed for renewable energy generation and distribution projects, possibly based upon the University of Aberdeen and Macaulay Institute report;
- as the use of the term "pristine" can be used to undermine the biodiversity and carbon storage value of upland ecosystems, the term should be changed to "valued";
- an EU strategy is developed to ensure renewable energy policy and development projects are linked to and do not undermine environmental protection of biodiversity, habitats, species and stores of carbon stocks, and;
- Article 6 of Directive 2001/77/EC, together with the proposed Article 12 of COM(2008)19 are amended by future legislation to ensure they are in keeping with the Gothenburg Agenda and EU Directives and Communications with regard to environmental protection and the safeguarding of biodiversity, habitats, species and stores of carbon stocks.
Scottish Government
- That the recommendation of the Scottish Government's Rural Development Strategic Environmental Assessment is enacted and that a National Renewables Energy Strategy for Scotland is produced which guides developers away from environmentally sensitive sites;
- That the Scottish Government ensures that it meets its obligations under the Habitats Directive, particularly Article 10 and;
- That the Scottish Government should base future rural development and renewables policy decisions on "sustainable development", as defined by the Brundtland Report as "development that meets the needs of the present without compromising the ability of future generations to meet their own needs."