Αυτό είναι το σχέδιο νόμου για την χωροθέτηση αιολικών πάρκων μέσα σε περιοχές NATURA!!δόθηκε εντολή απο το ΥΠΕΚΑ στο μελετητικό γραφείο, το οποίο και πληρώθηκε για την δουλειά του!!
Κυριακή, 25 Σεπτεμβρίου 2011
Σάββατο, 24 Σεπτεμβρίου 2011
Δημοσιεύουμε το κείμενο όπως μας ήρθε!αν θέλει κάποιος φίλος η φίλη να το μεταφράσει επώνυμα και να μας το στείλει θα το δημοσιεύσουμε και στα ελληνικά!
The shame of Scotland
AFTER NAVARRE, SCOTLAND MAKES A MOCKERY OF THE LAW AND HELPS WIND FARM DEVELOPERS RAVAGE THE LAND.
Environmental impact assessments and monitoring studies have become tools of deceit in the hands of unscrupulous developers. But they would not succeed if it were not for the complicity of politicians, civil servants and, most surprisingly, ornithologists and bird societies. Scottish authorities are on their way to disregarding reality entirely. Between collision modelling and use of the PAT model, they are able to approve the implantation of windfarms wherever eagles fly in Scotland. The EU Wild Birds & Habitat Directives are being outwitted, and the Scottish eagles are doomed.
Above picture : El Canto wind farm, Burgos, Spain. Placing wind turbines on ridges and hilltops cause many deaths among soaring birds (e.g. eagles and other raptors), birds crossing from one valley to the next, and migrating birds In previous works I have exposed the cover-up that has kept the public misinformed on the subject of bird mortality at wind farms (1) and on the role played by governments and NGO´s (2). I wish to denounce, now, some of the deceptive methods being used in the planning process, which lead to the approval of ill-sited wind farm projects that will severely harm protected bird species. Scotland has distinguished itself in these deceitful practices. The Scottish moors are windy, and this attracts wind farm developers. But instead of erecting the turbines where they won’t harm protected bird species, they pick the worse possible places, such as hilltops where eagles soar. New power lines, needed to transmit electricity from such remote locations, also kill eagles and other birds. But the death of protected wildlife weighs less in Scotland than the maximisation of profits for influential shareholders. At stake is the survival of the white-tailed sea eagle, recently reintroduced, and numbering only 42 breeding pairs; that of the golden eagle, 443 pairs, described by Whitfield et al. 2006 (11) as being in "demographic difficulty"; and the sustainability of healthy populations of red-throated divers, black-throated divers, ospreys, red kites (recently reintroduced), hen harriers, peregrine falcons, merlins, golden plovers, swans, geese, corncrakes, etc. Scottish golden eagles, for instance, cannot possibly sustain the impact of additional mortality caused by wind farms and new power lines situated in their habitat. Their mortality is already excessive due to other causes, and wind farms are known to be particulartly deadly to eagles: in California alone, 2,300 golden eagles were killed by wind turbines over 20 years (3). Here are some of the methods being used to mock the law: 1 - REASONING LIKE POACHERS, 2 - SALAMI-SLICING, 3 - THE CORE-RANGE MANIPULATION, 4 - THE NEW-EVIDENCE CAPER, 5 - THE SITE-SPECIFIC HYPOCRISY, 6 - THE DISPLACEMENT EUPHEMISM, 7 - THE HABITAT ENHANCEMENT FABULATION, 8 – CRYSTALBALLING, 9 - COMPUTERIZED BIRDS, 10 - DISREGARDING THE MOST LAXIST GUIDELINES, 11 - NON-PRECAUTIONARY PREDICTIONS, 12 - PREDICTING THE ACCEPTABLE, 13 - THE PAT MODEL, 14 - THE DOWNSIZING ILLUSION, 15 - THE LOCAL POPULATION FOCUS-POCUS ( sic! ), 16 - THE PREY-ENHANCEMENT FAIRY TALE, 17 - OTHER COUNTRIES, 18 – CONCLUSION
1 - REASONING LIKE POACHERS The following report was published in 2006: 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. Says the summary : “...only 2% of habitat predicted to be suitable for non-breeding eagles overlapped with proposed or installed wind farm areas.” This is a half-truth, the most effective disinformation technique there is. Indeed, what remains unsaid is that these 2% are mainly ridges and hilltops, i.e. topographical features that the young eagles will use preferably to the rest of the “suitable habitat”. - It is not unlike a poacher telling the game warden : but... I only put my traps on animal trails, and these only represent 2% of the whole forest ! . Yet the authors of the report are specialists in their fields, highly regarded in Scottish ornithological circles. Two of them give their addresses as being SNH ( Scottish Natural Heritage - an agency of the Scottish Executive ). This surprising behaviour may be explained by the strong conflict of interest that undermines the ornithological profession worldwide, including bird societies : the windfarm industry has become the main employer of ornithologists. Another is the public administration : environmental and energy agencies that are accountable to governments, who happen to be promoting the carpeting of much of the world with bird-killing wind turbines. Bird societies also employ ornithologists, but they have placed themselves in a like conflict of interest by accepting donations or otherwise dealing with electrical companies and other interests related to windfarming. As a result, most bird societies in the world today are actively supporting the turbinisation of the countryside, in spite of the slaughter of birds it will cause. Regrettably, the RSPB is one of them. Their financial interest in "RSPB energy" is only the most visible manifestation of what they have become. They failed to react when senior ornithologists like the above took a poacher´s approach to bird life.
2 - SALAMI-SLICINGThe wind industry insists, and hired-ornithologists agree, that each wind farm application should be judged on its own merits, and processed on a case-by-case basis, in isolation from others. There is a failure to consider the cumulative effect that wind farm multiplication will have on vulnerable bird species; yet there are 500 projects for Scotland, which is a considerable number (4). Developers admit that 22 eagles may be killed at the Edinbane-Ben Aketil windfarms, 50 at Lewis ( original application ), 12 at Eishken, etc. ( all self-serving predictions, with actual mortality likely to be a multiple of these numbers ). Yet SNH will not consider the cumulative effect of these 3 projects, let alone 500 of them. European law ( 79/409/EEC and 92/43/EEC ) calls for the protection of vulnerable bird species and their habitats. So does UK legislation. Dividing the risk to bird populations into 500 isolated segments has the effect of misrepresenting that risk immensely. Thus, the "salami-slicing" of the impact effectively violates the law. Surprisingly, bird and nature protection charities only pay lip-service ( when they say anything at all ) to the need for a strategic impact assessment. Failing to oppose the case-by-case approach of the industry, they disregard the basic principle of conservation : cumulative effect. That will be disastrous for biodiversity. NGO´s are very keen to promote renewable energies, with little regard to actual efficiency in tackling global warming. We have found that conflicts of interest may be causing this blind commitment. The RSPB, for instance, allows Scottish and Southern Energy to market a product called "RSPB energy" ( a Google search with these 2 words will provide details ). Households are told that, by paying a bit more, they will help develop renewable energies ( i.e. mainly windpower at the moment ). And the "RSPB" in the name of the product effectively guarantees in their minds that wind farms won´t harm birds. - This is deceitful. Fees are being paid to the RSPB in proportion to the number of signed-up customers.
3 - THE CORE-RANGE MANIPULATIONA pair of adult golden eagles will settle on a "breeding range" having one or more possible nest sites and sufficient prey. Ornithologists consider that this range, in Scotland, will on average cover an area roughly equal to a 6-9-km-radius circle around the territory’s centre (5). Wind turbines do not belong on golden eagle breeding ranges, lest we are willing to kill them : there is ample evidence of eagles being struck by turbine blades around the world (3), and two experiments in Scotland have resulted in failures ( see THE DISPLACEMENT EUPHEMISM and THE HABITAT ENHANCEMENT FABULATION further down) . But eagle ranges are prime targets for the wind industry, bringing windfall profits for the following reasons: 1 - the ranges normally include ridges, slopes, or hilltops, where the wind blows stronger. Eagles favour such topograpical features for the presence of declivity winds, which give them lift. Besides, ridges and hilltops offer commanding views over their ranges. 2 - leasing comes cheap, as there is no competition from other industries or commercial activities. Money being such a strong incentive, a way was found to despoil the eagles. Imaginative consultants, hired by a wind farm developer, abandoned the inconvenient truth of breeding ranges having a 6 to 9-km radius. They used another concept : the “core range”, defined as a 3km-radius inner circle around the territory´s centre. They declared, arbitrarily, that this was the area that had to remain free of wind turbines ( Dulas Ltd, Habitat and Ornithological Assessment, Pentland Road Wind Farm, September 2002 ). SNH did not challenge this. They too disregarded the rest of the range. The consultants did not have to provide a justification for such an arbitrary and life-threatening (for the eagles) concept. - They would have been hard-pressed to explain why turbine blades could kill eagles within 3 km of the territory´s center, but not beyond. Thus, Dulas Ltd won the day. Pentland Road was approved, targeting an eagle range within an "eagle reserve" ( the Lewis peatlands Special Protection Area ). This sent a powerful signal to developers : environmental statements didn´t have to stick to reality. Imaginative ornithology and junk science are acceptable where wind farms are concerned. This being the case, things went a step further. In 2006, the core-range trick was institutionalised, so to speak, by Alan H. Fielding, D. Philip Whitfield and David R.A. McLeod in their report : SPATIAL ASSOCIATION AS AN INDICATOR OF THE POTENTIAL FOR FUTURE INTERACTIONS BETWEEN WIND ENERGY DEVELOPMENTS AND GOLDEN EAGLES AQUILA CHRYSAETOS IN SCOTLAND
(2006). They wrote : “Although there were records for over 500 wind farm proposals at various stages of development, relatively few coincided with eagle territories (ca. 4% of territories had a proposal within 3 km of territory centre).” Thus, by a stroke of their pen, Scottish eagles had been despoiled of ca.70-90% of their ranges. Playing with the word "territory", which is the smaller area that the eagles will defend, they conveniently forget that the birds hunt over their whole ranges. Thanks to Dulas Ltd, thanks to A. Fielding et al., thanks to the silence of SNH and the RSPB about this manipulation, wind farms will be installed on eagle ranges as if eagles only flew within their "core-ranges". A triple crime is being committed : one against the eagles, who will become extinct as a result - see : Windfarms to wipe out Scottish eagles ; another against science (obvious) ; and a third against the reputation of all concerned, not least that of the RSPB. Little does it matter to these "conservationists" that golden eagles are attracted by wind turbines, as shown by scientific observation (6). Besides, there is plenty of evidence of eagles being killed by wind turbines - see : Eagles and wind farms : mortality statistics Reality is being scorned upon. Ornithologists have constructed a make-believe world that will accommodate the interests of their employers. If this weren´t enough, their core-ranges are too being violated : 18 wind farms will be built within them , as revealed by the previous quote from the Fielding et al. report : 4% of the 443 breeding territories that are active in Scotland. We don´t hear SNH or the RSPB complain about that either. The question is : will the European Commisssion endorse that as well ? It would make a mockery of their Birds & Habitat Directives, and of the EC being serious about preserving biodiversity . Climate change is not acceptable as an excuse : it is criminal lunacy to kill our protected birds today lest they might get killed tomorrow. Birds have adapted to more abrupt climate changes in the past.
Above picture : head of golden eagle decapitated by a rotor in Aragon, Spain - courtesy of EL SEKANO . Turbine blades can reach 300 kmh at the tip - see : PRELIMINARY CONSIDERATIONS ON AVIAN MORTALITY in the following article : Chilling Statistics
4 - THE NEW-EVIDENCE CAPER SNH practiced that trick themselves. Here is how : Dulas Ltd, consultants to the Pentland Road windfarm developer, had made a survey of birds breeding within the turbine area. They had found, among others, 10 pairs of red grouse, which were deemed to be of importance as prey for the resident golden eagles - that´s 20 adult grouse plus their broods. SNH had objected to the project, which targeted a GE breeding range within the Lewis SPA . But pressure must have been applied on SNH because, quite suddenly, they lifted their objection. They explained that they had received "new evidence", as follows : 1) They had conducted their own survey, in one day, “with 2 men and a dog”, and claimed they had found only 2 pairs of grouse. It did not seem to matter that a more thorough survey by the developer’s consultant had found 10 pairs. 2) And they added : "we have also received information ( from other wildlife consultants carrying out observations in Lewis ) confirming that this pair of eagles are more often seen using the area of blanket bog to the north west of the hills rather than the area where the turbines are proposed." Yet there were charts prepared by Dulas Ltd showing eagle flights near the future wind turbines, as actually recorded during field work. And what is the value of "more often"? Are the "less often" flights among the turbines any less dangerous? - This is pure spin. Conclusion: as evidence presented by the developer showed unacceptable impacts on both grouse and eagles, SNH thought nothing of discarding them. This is a case where the prosecution (SNH) is more lenient than the defending lawyer (the developer´s consultant) - something unheard of.
5 - THE SITE-SPECIFIC HYPOCRISYAs developers keep targeting the best eagle habitat in Scotland, eagle-kill statistics from wind farms around the world have become embarrassing evidence against such projects (3). But ornithologists are not immune from hypocrisy, especially when money is at stake. So the argument being aired is that wind farms in Scotland will not necessarily kill eagles as they do in other parts of the world. It is the “site-specific approach”. The site-specific approach may be appropriate to other endeavours, but not when it comes to traps, guns, and other killing devices. Imagine fishermen arguing that tuna nets known to kill dolphins in the Pacific would not necessarily kill dolphins in the Atlantic. Preposterous as it would be, people with bad faith could hold onto such a line of argumentation until proven wrong by the facts. But if they do the monitoring themselves, the facts will be under their control. The dolphins are lucky ( so to speak ) : independent observers board fishing boats to see for themselves. But when it comes to birds and windfarms, independent monitoring is unheard of. Those in charge are ornithologists hired by the windfarm developer. And in Scotland, dead birds are not found, for hired ornithologists don’t search the ground under the turbines : they are only paid to look at the sky from distant vantage points, studying eagle behaviour in the windfarm area. This is notably the case of the Beinn an Tuirc windfarm. At Beinn Ghlas, there was no behaviour to observe, as the eagles vanished from the first moment. And mortality searches were not on the programme. Not a single windfarm was systematically monitored for mortality in Scotland..
6 - THE DISPLACEMENT EUPHEMISMAbout seven years ago, using the site-specific argument, a wind farm was built on a golden eagle range at Beinn Ghlas, Argyll, Western Scotland. But the great birds were never to be seen again. There was no indication they had established themselves elsewhere - this would have been surprising, as evidence from abroad shows that wind turbines attract golden eagles, rather than the opposite (6). It was also impossible to tell if they had been killed by the rotors, as ornithologists were not required to search for carcasses. As nobody could prove the eagles had been killed, the wind farm operator declared that the eagles had been “displaced" by the turbines. SNH did not dispute the word : this interpretation will not hamper the constru.The Beinn Ghlas windfarm may have killed two eagles. It may also have killed more, for when a resident eagle dies, another normally takes its place, pairing with the survivor. If both resident eagles die, another pair will form on the vacant range, as long as there are young eagles roaming about the country, looking for such an opportunity. What I am suggesting is that Beinn Ghlas may be acting as an ecological trap. But the official word is that the eagles have been “displaced”. Surprising is the fact that the RSPB did not protest. What is more, they continue to accept that wind farm developers target eagle territories throughout Scotland. They do sometimes submit objections on an ad hoc basis. But it is too little, too late, and the projects are generally approved. This lack of resolve by the bird charity has prompted criticism, but the press has remained silent on this, protecting the reputation of the “Old Lady”. The recent negation to oppose a huge windfarm in the Shetlands, which are an important migration staging post, was interpreted by a newspaper as a sign that the RSPB were favouring their business partners, Scottish & Southern Energy ( the Shetlands windfarm developer ). More generally, the declared pro-windfarm policy of the RSPB is being used by windfarm developers as moral support for the devastation they cause.
7 - THE HABITAT ENHANCEMENT FABULATION
To explain why Scottish eagles would be safe, whereas their foreign counterparts are routinely being killed by wind turbines, consultant ornithologists developed the concept of "habitat enhancement", also called “habitat management”, or "land management". The idea is to “manage” the eagle territory so that the great birds would change their flight patterns, staying clear of the turbines erected on their range. A well-publicised experiment was made at the Beinn an Tuirc wind farm, on the Kintyre peninsula. A few hectares of forest were felled on the eagles’ range in the hope that, within 5 to 7 years, it would become suitable habitat for grouse, which in turn would attract the great raptors away from the wind turbines. This did not happen, as there is now talk of introducing mountain hare. But what did happen is that the eagles´ breeding success dropped to zero from the moment the first surveyors started to move about their range in 1997. What is more : in late summer 2006, we were told that the male eagle had disappeared. It may have been killed by the turbines, but as no monitoring for dead birds is being conducted, it is not possible to find out. More eagles may have died, either intruders or new residents; we shall never know : the original resident pair was not tagged, or identified by close-up pictures, so who can tell if one bird was killed, or several? The B an T windfarm may be already acting as an ecological trap for eagles. But neither SNH or the RSPB have asked that this should be investigated. Adding insult to injury, the Beinn an Tuirc fiasco went on the official record as a success ( Walker et al, Scottish Bird, June 2005 ). The wind industry went a step further, pretending that the conservation status of the GE species had been improved (sic) (David Fotheringham, Scottish Bird News, March 2006 ). And… the windfarm owner has now received permission to erect dozens of additional turbines, extending the danger zone further along the mountain crest. As I said before, junk science and misrepresentation are an essential part of the windpowerisation of Scotland.
8 - CRYSTALBALLINGSome windfarm projects have such large footprints that several pairs of eagles will be affected - e.g. Eishken, which will lie within a designated Important Bird Area, and North Lewis, in a Special Protection Area. There are also projects targeting locations where many young eagles routinely come to hunt, soar, or interact with one another. These are called “dispersion areas”. The Edinbane and Ben Aketil windfarm projects, on the isle of Skye, are in one of them. In such cases, it is not possible to deny that some eagles will be killed by the wind turbines. So the focus is shifted to numbers, and hired ornithologists play down the significance of the kills. Regarding Edinbane, for instance, they say : our project will kill 15 eagles over 25 years, but that will not significantly affect the local GE population. What they don´t say is that it will affect the population of mainland Scotland, which is deficient and needs immigrants from the Hebridean islands to maintain itself – see : THE LOCAL POPULATION FOCUS-POCUS further down. Besides, such predictions are self-serving. In reality, as mortality figures from around the world have shown (3), many more eagles will die at Edinbane : as much as 1,000% more ( see next section : COMPUTERIZED EAGLES ). The predictions are based on an exercise called modelling, whose results vary widely according to the chosen parameters. Besides, the data being fed into the computer may itself be corrupt. Take, for instance, eagle flights as recorded by the hired observers at Edinbane : only considered are those estimated to have occurred between 20 and 100 meters above ground level. This raises four issues : 1 - There is a probability of error in estimating flight heights, particularly when the observations are made from hundreds of meters away. They cannot be made from closer up, as human presence deter these human-wary raptors. 2 - There is no construction on the hill where the windfarm is to be built, therefore no yardstick that would help estimate the flight height correctly. 3 - Too many eagle flights in the danger zone are a problem for the developer. Ornithologists working for him know that, and it is their best interest to please their employer. This is called a conflict of interest4 - How many flights are missed by distraction? During the course of a day, it is not possible to keep looking at the sky, 360º, during 10 hours non-stop. Radar monitoring has shown that many flights are missed by human observation ( Largie Environmental Statement ). Every piece of information being fed into the model will impact the results : not only flight height, but flight distribution area, and flight speed. Flight speed, for instance, was considered to be of 13 m/s ( 47 kph ) for the Edinbane model. But this is unrealistic. It is assumed that the eagles will behave like inanimate objects, like stones that would be thrown across the rotor-swept area. Not considered are the effects of hesitation, circling, surfing the wind to the point of remaining still, and other eagle flight behaviours that may slow the speed of crossing, thus causing more collisions. Just as important is the data that is NOT being used : birds that are excluded from the study ( e.g. intruding eagles in the Beinn an Tuirc monitoring study ), birds that are mistaken for intruding eagles ( e.g. the resident pair in the same study ), and flights that go unnoticed ( those outside the hours of observation - eagles even fly at night, sometimes – or when the observers are distracted ). In other words, erroneous, biased, or incomplete input will produce incorrect results. Says the British Trust for Ornithology, who published a critical study of the SNH collision model : "Errors in bird counts and numbers at risk height will translate into directly proportional errors in predicted mortality rate." (7). A study by Mike Madders & D. Philip Whitfield (March 2006) (said essentially the same thing: “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.” (15) This last sentence cautions about the use of “avoidance rates”, which have a drastic effect on results. But these sensible remarks have been disregarded : a high avoidance rate of 98% was decreed by SNH for the golden eagles at Edinbane. A rate of 95% was considered for a while, recommended by ornithologists. But this would have produced a collision rate of 5.5 eagles per year, i.e. 5.5 x 25 years = 137 eagle collisions ( for the original layout of 27 turbines ). It would have caused the project to be defeated, and the eagles saved. With 95%, even a downsized project would not have been acceptable. But SNH chose 98% instead, which produced a prediction of 15 eagles for the downsized 19 turbine layout. This was the upper limit they had set for Edinbane´s eagle mortality. They could then lift their objection, and permit the killing of 15 eagles, on paper. In the real world, mortality may be closer to 150.
9 - COMPUTERIZED BIRDS
Besides postulating that golden eagles fly at 47 kph when passing though a rotor, collision modellers make other assumptions : - They assume that the birds always fly through the rotor at a right angle. This has the effect of minimising the collision prediction. At any other angle, the exposure to danger would be longer. - The timing of the crossing ( flying through the rotor ) is disregarded. Yet it is a consideration of capital importance: Unlike objects, birds make decisions. If the crossing appears dangerous, e.g. if a turbine blade happens to "swoosh" in front of the eagles as they are about to cross, chances are they won´t attempt it. Thus, it is less likely that they will cross when a blade has just passed. Yet it would be the best possible timing, yielding the lowest possible risk. Conversely, they are more likely to cross if, when they happen to look towards a turbine, they see a wide opening. A decision is made to cross, but by the time they reach the blade-swept area, the next blade is about to strike. So we can reasonably assert that birds will cross the danger zone at the worst possible moment. This is not taken into account by collision models, whose treatment of birds as objects has the effect of minimising mortality predictions. Another factor is ignored by modellers : wind. Here is what wrote D. Philip Whitfield on the subject : 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. (18) And here is the opinion of the ornithologists who know the Skye eagles better than anyone, having studied them for 20 years : "... by the overriding use of modelling little concern is being shown for the actual situation on the ground." Actual mortality, in view of the multiple shortcomings of collision modelling, may be higher than forecast by as much as one order of magnitude (1,000%). This is evidently cause for "reasonable doubt" as regards the effects of the Edinbane and Ben Aketil windfarms on the Cuillins SPA. But it goes beyond. All windfarm projects affecting eagles should be re-assessed. Other protected bird species may also be more at risk than we have been led to believe.
10 - DISREGARDING THE MOST LAXIST GUIDELINES
To give a sense of perspective, here is a mortality prediction as calculated by Dr Jeremy Carter in his objection to the Ben Aketil project ( sited on a hill adjacent to Edinbane ) :” 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 applicant’s 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." Note : young eagles from other parts of Scotland are likely to fly over the hills of Edinbane and Ben Aketil once or several times during their non-breeding years - roaming is normal behaviour for immature eagles. The twin windfarms would become an ecological trap for new generations of these great birds. 11 - NON-PRECAUTIONARY PREDICTIONS Scientific predictions are always accompanied by a margin of error, or “margin of uncertainty”. But not in Scotland : estimates of future eagle kills, spanning 25 years, are precise to the unit. This is un-scientific. In addition, the precautionary principle is not being applied. On the contrary, everything possible is being done to minimise impact predictions. SNH, whose raison d’être it is to defend the country’s natural heritage, is being perceived as helping the developers to erect their wind turbines within protected areas such as SPA´s, IBA´s, and the highest-density eagle habitats. Apart from Edinbane and Ben Aketil, precise-to-the-unit mortality predictions have been made for other windfarm projects, including one sited within an SPA ( the Lewis Peatlands ), and another one located within an IBA ( Eishken, IBA UK224 ) .
12 - PREDICTING THE ACCEPTABLE Consultants who run the model sometimes know in advance the number of kills that should not be exceeded in their prediction. It was the case for Edinbane, where SNH placed the limit at 15 eagles over 25 years (8). This number was based upon the knowledge of golden eagle productivity in the island, including the Cuillins SPA. It is easier to make a prediction when one knows the number that HAS to be predicted. We are entitled to wonder if the avoidance rate of 98% would have been chosen by SNH if it hadn´t permitted the developer to predict a mortality of 15 eagles.
13 - THE PAT MODEL The project of Inverliever, in Argyll, was to occupy the best part of a ridge situated on the territory of a breeding pair of golden eagles. The consultant drew a map showing the flights, not only of eagles, but of other protected birds ( such as red-throated divers, hen harriers, and merlins ), that were using the site. The controversy, as usual, centred on the eagles. To circumvent the damning evidence, the PAT model was used ( PAT = Predicting Aquila Territory ), which “predicts” that the eagles fly preferably close to their nests. This way, the ridge that was targeted by the developer was declared of little interest to the eagles, in contradiction with both logic ( eagles soar on declivity winds that culminate on ridges ) and observed behaviour ( the recorded flights ). For more details: Birds and Windfarms - The use of junk science in Scotland. - SEE SECTION 1, INVERLIEVER ( ARGYLL ). SNH had aided and abetted the efforts of the consultant by supporting the use of the PAT model. In the end, however, critiques made it difficult for them to disregard reality so blatantly. Politics also played their part, no doubt. Thus, forgetting about the eagles altogether, SNH decided to oppose the project on landscape grounds. Logically, next time around consultants will not be required to conduct observations on location. This way, reality will never again contradict the PAT model. This has been suggested already, under the pretext of saving money to the developers... Scottish authorities are on their way to disregarding reality entirely. Between collision modelling and use of the PAT model, they are able to approve the implantation of windfarms wherever eagles fly in Scotland. The EU Wild Birds & Habitat Directives are being outwitted, and the Scottish eagles are doomed.
14 - THE DOWNSIZING ILLUSION When bird mortality predictions, however manipulated and minimised, are still judged excessive by SNH, developers withdraw their applications and submit new ones, for a smaller number of turbines. Lewis, Eishken, and Edinbane were downsized in response to their unacceptable impact on protected bird species. By running the model over and over again, and testing various turbine layouts, it is not difficult to find one that produces an “acceptable” number of collisions. Parameters may be changed, new evidence may be added... When one enjoys the support of the government, ways are found. The effect of downsizing is illusory, first because of the wide margin of error inherent to computer modelling ( as much as 1,000% ) – e.g. at the Australian wind farm of Woolnorth, where 1 eagle collision per year had been predicted, 3 eagles were effectively killed in 3 months, by 33% of the turbines ( the others were not monitored ). The other reason is that wind farms can be extended at a later date. Experience shows that extensions are easy to obtain, as opponents have normally given up the fight. Beinn an Tuirc, for instance, is being extended without opposition ( in spite of the dismal effect on the eagles – see earlier section : The Habitat Enhancement Fabulation ). Downsizing is taking a step backwards to jump further ahead.
15 - THE LOCAL POPULATION FOCUS-POCUS ( sic! ) This trick was first used at the Altamont Pass windfarm, California, where 2,300 golden eagles have been killed over 20 years (10). As concern grew over this important mortality, a 5 year study was made of the local GE population. The final report concluded that the breeding eagles living in the surrounding area had not diminished in numbers. But the study is irrelevant : the local population is not the one that suffered from the losses. The others did. Let me explain : The wind farm is located in a prey-rich dispersion area*, attracting young eagles from other parts of California, and from other states and countries. It may be the most important GE dispersion area in the world. Breeding adults have their territories outside the area : they normally do not enter the danger zone of the turbines. The 116 yearly victims are mostly immature eagles (10). --> * dispersion areas : territories that offer abundant prey but no nesting sites. For that reason they are not claimed by breeding eagles, and therefore are not defended against intruders. Non-breeding eagles hunt and interact freely in these areas, coming from as far as thousands of kilometres away. At Altamont some are migrating adults, looking for food in warmer climates, but most are immature eagles, who roam about whole countries for about 4 years before settling down in a territory of their own. When a local breeding adult from the surroundings dies from whatever cause, it is quickly replaced, as there are plenty of floaters in the nearby dispersion area, always looking for an opportunity. So, in effect, the local population will be affected last by the killings taking place in the windfarm. The populations to be affected first are : 1 ) the Western Canada GE population, when some of its wintering adults and immatures are killed at Altamont Pass, 2 ) the Western United States population, when some of its breeding adults are not replaced because of a paucity of floaters caused by the ongoing Altamont killings. In short, the effects will be felt on the GE population in California and beyond, while the local population of breeders will remain stable. The local scope of the G. Hunt research is therefore inappropriate, and leads to deception. A subterfuge of the same ilk is being applied in Scotland for Edinbane and Ben Aketil. Skye island has a healthy golden eagle population, which provides immigrants to the mainland : there, persecution and other hazards ( e.g. power lines ) would cause the population to decline if it were not for immigration from Skye and other Hebridean islands. Whitfield et al (2006) have identified the island as a population source for the mainland region directly across the water. Referring to the deficient reproduction rate of golden eagles in the Western Highlands (NHZ zone 8), they state: "The most likely source of immigrants was the neighbouring NHZ 6* ( Western Seaboard ) where high occupancy has been stable for decades and demography appeared to be sufficiently favourable." (11) --> * NHZ 6 is composed of Skye + small nearby islands. Yet, SNH chose to ignore the dependence of the mainland population on immigration from the islands, and decided that eagles could be killed on Skye. They estimated that the Skye GE population could withstand the killing of 15 + 7 eagles over 25 years ( Edinbane + Ben Aketil ). But they failed to take into account that these 22 eagles* are needed to keep the population of the mainland from declining. --> * 22 victims if an avoidance rate of 98% is also applied to Ben Aketil ( instead of 99.5%, the old rate that caused so much criticism ). The overall GE population of Scotland is in demographic difficulty ( Whitfield et al. 2006 ), meaning that it is expected to decline if all things remain equal. Therefore, ANY additional mortality on Skye will tip the scales, launch the decline sooner than thought, and make it more severe. And to windfarms on Skye must be added those on Lewis, and on dozens of other eagle territories across Scotland. The cumulative effect has not been studied