EREF’s comments on EEA approach to establish an environmental-compatible wind energy potential

1. EREF’s comments on EEA approach to establish an environmental-compatible wind energy potential EUROPEAN RENEWABLE ENERGIES FEDERATION asbl Dr.Dörte Fouquet www.eref-europe.org info@eref-europe.org +3226724367 +3226727016 fax

2. Climate change – the terminator to Health, Flora, Fauna and Habitat • “Using fossil fuels -- coal, oil and natural gas -- to make electricity dirties the nation's air, consumes and pollutes water, hurts plants and animal life, creates toxic wastes, and causes global warming. Using nuclear fuels poses serious safety risks. Renewable energy resources can provide many immediate environmental benefits.. “ (Union of Concerned Scientists, http://www.ucsusa.org/clean_energy/renewable_energy_basics/public-benefits-of-renewable-energy-use.html) • Coal and Nuclear - neither clean nor sustainable

3. Wind energy protects nature – coal kills it • Wind Energy in Germany alone saved CO2 emission in 2005 by 23 Mio t and produced 26,5 bio MW The wind Energy Industry aims to save yearly 86 Mio tons by 202 • A Typical 500-megawatt coal plant produces 3.5 billion kilowatt-hours per year. It burns 1.4 million tons of coal (the equivalent of 40 train cars of coal each day) and uses 2.2 billion gallons of water each year and emits • 10,000 tons of sulfur dioxide • 10,200 tons of nitrogen oxide, equivalent to half a million late-model cars • 3.7 million tons of carbon dioxide, equivalent to cutting down 100 million trees • 500 tons of small particles • 220 tons of hydrocarbons • 720 tons of carbon monoxide • 125,000 tons of ash and 193,000 tons of sludge from the smokestack scrubber • 170 pounds of mercury, 225 pounds of arsenic, 114 pounds of lead, 4 pounds of cadmium, and other toxic heavy metals • Trace amounts of uranium • How many species are lost on an average year in Europe by transport and fossil fuel power plants?

4. Policy buttom up - Approach in planning for RES development has priority • Manifested in various Directives, such as Directive 2001/77/EC, Biofuel Directive, Green paper on energy • National Energy Policies • But top down analysis can help to be corrective tool

5. Wind Energy Production as privileged public interest task – is the starting point for sustainable planning • Only important dissenting public interests can prevent development of Wind energy (see principle established in German planning and building code, § 35 BBauG) • Planning should be advised, should be best based, on National/Regional guidelines which can also rely on European data base and recommendations • Listing of protected areas and areas for development of Wind energy (and other RES) should be favoured in the interest of security and common understanding • But categorical No even in IBA is unnecessary –all depends the concrete planning case and situation, careful EIA etc., including cumulative approach of assessment

6. Spatial Planning – competence of Member States only • European Commission respectively EEA may advise and help in giving important guidelines for assistance to MS to rapidly increase use of RES technologies under the framework of Directive 2001/77EC in an efficient and sustainable way, decreasing barriers as obligation • EIA Directive and strategic Planning and Programming execution in the sole competence of MS – Again EEA may give general non-binding guiding lines to avoid breech of EIA rules • FFH/OSPAR – no direct right for EEA/Commission to directly prescribe legally binding planning rules • Priority consideration to be given to the recommendation of the Green Paper for the Security of Energy Supply (European COM(2000) 769 final, page 44), which calls for a clear priority of renewables in the land use plans at the national, regional and local levels

7. Progressive RES Member States’ Experience as main source of reference • EEA should restrict its role to a strong and positive messenger for best available practice for wind development in best balance approach coming from countries such as Germany, Spain, Denmark – and provide data base for lessons learned • No need for active control and restriction role of EEA but for platform host for experience pool in cooperation with the respective Environmental Agencies especially from RES progressive countries

8. Considerable flaws in EEA questionnaire and documentation – Main examples • Clear Commitment for rapid promotion of wind power development by EEA is missing • Assumptions of EEA are too rigid and not considering urgency, spatial and political conditions which imply need for flexibility and room for adjustment • EEA approach, fundamental assumptions and the structure of the questionnaire do not take respect the particularities of the spatial environment and of the wind energy potential in mountainous regions such as in Greece. On the contrary, the original questionnaire has been structured around the basic idea that wind energy installations are mostly developed in extensive plain (flat) landscapes or at sea. Attempting to fill-in the questionnaire, even with just some comments pertinent to differences in different regions, will lead to serious misunderstandings. In addition, possible application of the project’s proposed approach especially to Greece will result in a deadlock situation, practically nullifying further development of wind energy in the country. The corresponding categorisations of the questionnaire meets same criticism.

9. Greece as litmus test for EEA approach • Mountainous states lack of open plain landscapes with adequate wind potential. The wind potential is mostly concentrated in mountainous area with complex terrains. This fact has a number of very specific consequences: • The visual effect is not very much related to the distance of the wind park from the view point, neither to the ratio of the area occupied by the wind turbines in relation to the total land area. Common phenomenon to have a concentration of wind turbines on an isolated hill, but these turbines to be completely hidden from nearby cities and human activities, because they are behind higher mountains. • The concentration of wind turbines on the top of mountains leaves intact, without any intervention, large hill-side areas or flat areas between mountains. Thus, the application of any coverage ratio to the mountainous area will certainly lead to the rejection of any proposed wind park, while the result will be different if the same ratio is applied to a broader land area (e.g. a prefecture).

10. Greece – litmus test II • The legal categorisation of land in Greece does not correspond to the categorisation of the questionnaire, and this will create serious confusions. Indicatively, it is mentioned that all the rocky areas or the areas with small bushes, which are not used for agriculture or urban development, are considered in Greece as forests or forestry lands. Almost 25% of the total land area in Greece falls into this category. More importantly, more than 90% of the areas which are suitable from a wind potential point of view (e.g. top of mountains), belong to this particular land category. That was the reason that the Greek law, as well as the relevant decision of the Supreme Court, have fully accepted the installation of wind parks in forests and 10 land, of course after estimation of the potential environmental impact. • Similarly, Greece is the Member State with one of the highest percentages of land areas included in the Natura Catalogue. This percentage is even higher and may exceed 30%, if one takes into consideration only the land areas with adequate wind potential. In parallel, the a-priori rejection of any wind installation in Natura 2000 or IBA areas is in contradiction to the Natura Directive and the national legislative framework, which permits the implementation of investments and works in these areas, under specific circumstances and restrictions.

11. Peer Review of existing literature and data pools steered by EEA more important • EEA could be the host for peer review on collection of sustainable wind energy development data, rather than aim for a supra-authority on wind energy planning • What literature collection is exactly available at EEA? What exchange is regularly, in detail and continuously done with National authorities, DG TREN, DG ENV, stakeholders? • Good, if EEA would look in representative sample overviews on authorisation procedures of concrete projects and of wind area planning on a structured base