Havsul 1 - Høringsuttalelse | Norges Miljøvernforbund

The Norwegian Environmental Protection Association (NMF) opposes offshore wind power plant Havsul 1's application for a postponed deadline to 01.01.2025 for commissioning, as well as demands that all granted licenses and permits be withdrawn.

The reason is an exceptionally high level of conflict, as well as the fact that any harmful effects on marine life from offshore wind turbine installations are inadequate and not sufficiently investigated.

There is a significant reason why concessions has and must have an expiry date. Concessions cannot be extended on "autopilot", even though NVE/OED has introduced a practice of granting such extensions. Each application for an extension MUST be assessed on an independent basis, regardless of previously incorporated practices or customs.

Original license was given completely back in 24.06.2008 and the knowledge base for the concession is very old and out of date. There is a lot of new and important knowledge that has now been added afterwards. In addition, there are a number of factors that are insufficiently or insufficiently investigated which can have a significant impact on biodiversity and marine ecosystems.

The fact that something has not been sufficiently investigated means that consideration of the given and any negative consequences must be taken care of according to the precautionary principle. The requested extension for commissioning must be rejected, and all granted permits must be withdrawn.

Major conflicts for marine ecosystems.

Major conflicts over the migration routes of a number of bird species.

Significant source of noise that can destroy the habitats of large marine mammals such as seals and whale species that are sensitive to sound and that use sound actively in communication and searching for food.

Several fish species also use sound to communicate. Cod, for example, has its own sounds that are used during spawning. Coastal cod is already in sharp decline, and Havsul 1 could have major negative regional effects.

Important rearing and spawning areas for fish are seized and affected.

Acute pollution hazard with release of hydraulic and gear oil.

Major source for discharge of microplastics directly into the marine environment.

Major conflicts with visual pollution.

Large overall load with many coastal wind power plants along large parts of the coast.

Update 27/3-2020:

NVE now has adopted extended deadline for commissioning for Havsul I.
I oversendelsesbrevet finner vi flere grove feil, mangler og utelatelser. Vi arbeider nå med en grundig klage. Dette anlegget har så mange og vidtgripende negative konsekvenser, og vi kommer aldri til å godta at dette blir bygget.

PS! The Norwegian Environmental Protection Association was granted a postponement of the consultation deadline by agreement with NVE/Arne Olsen

Update 2019-11-04:

Much new knowledge has been gained since the consultation response was submitted. These are things that absolutely should have been included in the investigation material before a decision was made. We strongly disagree that old and deficient knowledge should be decisive for a decision that involves so many and far-reaching negative effects.