New NVE report on impact assessments for wind power

Very good, but several years too late…

NVE published today (20/1-2020) its new report on impact assessments for onshore wind power. Here they review the entire licensing process and the report reveals major shortcomings with the current licensing system, and makes several suggestions for improvements.

The Norwegian Environmental Protection Association recognizes several of the mentioned points from our consultation input and from reports handed to the NVE director in the meeting.

The Environmental Protection Association gives NVE director Kjetil Lund great credit for his work in cleaning up the licensing processes for wind power.

He started his job as NVE director on the same day that the National Framework for Wind Power was presented on 1 April 2019, and has quite clearly put a lot of his prestige into cleaning up what has been a chaotic management regime for many years. It can hardly have been easy with a licensing department that has operated almost like a state within a state with its own systems and years of incorporated cultures and often uncultured in many contexts. The bureaucracy has its own ability to protect itself against external influences.

NVE director Kjetil Lund has clearly taken the right step here and set up a separate working group in which he has in all probability personally participated and supervised directly. The fact that this work has been in direct conflict with the licensing department's management came to light recently when a whole two MTA plans (Øyfjellet and Tysvær) were approved on the same day that the new oil and energy minister was appointed (Listhaug). Here the licensing department's power was to be demonstrated. To us, it seems as much a kick to the NVE director who now dares to interfere in the licensing department's internal structures and working methods as it was a clear demonstration of power towards the new minister. Two approved MTA plans on the same day is both extraordinary and unusual. Here, it was clearly to be demonstrated who really holds the power in NVE.

The Norwegian Environmental Protection Association is very satisfied with much of what has now been put forward, but at the same time there is a very long way to go before we can clean up the many issues that are already in the system. The work contained in the report and the weaknesses that are uncovered and with the proposed changes should have been taken up by former ministers and NVE directors. In that sense, this has been going on for several years and about 100 approved licenses too late.

The fact that the NVE director has so clearly stuck his fist right into the hornet's nest to clean up these old systems commands great respect. Kudos to Kjetil Lund for listening so clearly to our input (read more about this further down in the article), and for the work he has initiated and clearly has a strong hand at the wheel of.

Also read: NVE tightens the routines after a meeting with the Swedish Environmental Protection Agency

NVE has noted the resistance

NVE writes, among other things, its transmission letter to OED:

  • ...The working group was asked to consider measures for improvements in the light of those the experience NVE has gained from licensing work and developments in recent years, and in light of the popular commitment that has been and is about wind power.
  • But it is always possible to improve processes, and in recent years NVE has gained a lot of experience from this relatively new business in Norway. We believe that the package of measures we propose here, collectively or individually, will contribute to even higher quality, more legitimacy and less conflicts around concessions and development of onshore wind power.

More legitimacy and less conflict?

Over the past 15 years, the Norwegian Environmental Protection Association has worked against wind power. We realized early on the problems this would cause and that as climate measures they could not live up to the expectations they were advertised to provide. Through our ongoing work with wind power cases, we have repeatedly seen that we have been right from the start. It is more of a climate burden than a climate measure, and it destroys both natural diversity, the landscape, the local environment and local communities.

However, getting confirmation that we were right all these years does not solve today's problems. At the same time, this is also why the Environmental Protection Association has also increased its capacity and strength in the work to stop this single largest natural destruction of all time.

Now that the subsidy scheme with the "green certificates" (electricity certificates) is coming to an end in 2021, all the builders have also been in a huge hurry to start everything that can be powered up by excavators and dynamite all over the country. Everything is happening now, all at once. Now they are in a hurry.
The construction roads are blasted into the landscape at Vardafjellet, Sandnes

The conflicts intensify…

It is a myth that it was the work with the National Framework for Wind Power that was the cause of the great awakening and mobilization. This was something that the authorities and business interests told us. No, this was something else entirely. The panic and the rush to build as much as possible in the shortest possible time was what made the people wake up. At the same time, the media failed early on in their role as a neutral mediator. Here, they acted more often as a microphone stand for developer interests and lobbyists than for the opposing views. The great pressure from people and local communities, combined with the great flow of information on social media, has meant that even the common man and woman have had to express their opinion and share the facts.

NVE fails

A long series of very old concessions suddenly had their construction plan approved (MTA) and were now to be started. In practically all cases, the investigation material was both old, incomplete and out of date. In addition, NVE did not take account of updated knowledge, consultation input or received complaints. Here it had to be approved over a low shoe. Consideration of natural diversity, landscape, public health (noise), other industries or local communities was immaterial. Here, NVE was to knock through as many approvals in as short a time as possible. No form of reason reached the administration. In all cases, the benefit to society was greater than the disadvantages, according to NVE. And when the construction work started, it was no use complaining to NVE about mistakes and illegalities from the developer. No, NVE was gone without a trace when they were most needed...

NVE is blowing the environment... From action at Kjølberget in Finnskogen 2019 - Photo: NMF

Resistance and conflict are the only things that are useful

It is clear that the popular revolt against wind power has had consequences. As is well known, the National Framework for Wind Power was scrapped in the autumn. It was good that a comprehensive plan was drawn up, but unfortunately it came too late. It should have been in place doctor before the approx. 100 the licenses were awarded, not afterwards. Large parts of the country have already been destroyed, and in several places along our long coast and inland it is no longer possible to stand on a ridge without seeing one or more wind turbines at the same time. Evening and night, entire mountain peaks now stand and flash their powerful lights. The NRK concept Hurtigruten minute by minute could never have been carried out today. Now large parts of our beautiful coastline have already been eroded and destroyed by wind power.

The Norwegian Environmental Protection Association campaigned on 1 March 2019 at CICERO and NVE's meeting on the influence of people's acceptance of wind power by displaying a turbine-killed sea eagle from Smøla from the podium - Photo: Screenshot CICERO
The Swedish Environmental Protection Agency's head Kurt Oddekalv in conversation with new NVE director Kjetil Lund during the presentation of the National Framework for Wind Power on 1 April 2019. - Photo: NMF

The Swedish Environmental Protection Agency gets approval

With such strong forces working together to develop as much wind power as possible, active work is required on many fronts. We work with complaints, consultation statements, public meetings, information work, actions and training of shareholders and much more. In addition, we work actively with politicians and decision-makers. On 28 June 2019, we met with NVE director Kjetil Lund where we presented, among other things, our reports on climate accounting for wind power plants, unfortunate links between administration and developers, the smøllari rypa, which is threatened by wind power developments in all its habitats (Smøla, Hitra and Frøya), The Norwegian Environment Agency's "secret" report from 2015 where they criticized the licensing processes. In addition, we addressed a number of unfortunate aspects of the licensing processes and the lack of supervision of the construction sites and much else. This meeting was on a Friday, and already on the Wednesday of the following week a meeting was held letter from NVE to all builders about tightened routines.

Not only was this letter about new tightened routines sent out from NVE right after the Environmental Protection Association's meeting, but this working group which has now prepared this new report was also started at the same time.

The NVE director has clearly worked well in the background with clean-up.

What do we recognize from the new NVE report?

IN The Swedish Environmental Protection Agency's consultation response to the National Framework for wind power we set up 15 points for good management, where we went through point by point and highlighted significant errors and shortcomings with the current system. Much of this can be found again in the NVE report, and at the same time there are also several matters that we have raised in other consultation responses and complaints that we now find that NVE has now described and taken action on.

In chapter 2.17 Knowledge of the effects of wind power plants they write;

In several of the phases, it is a challenge that we sometimes have too little basic knowledge about certain topics. This applies to both knowledge about the effects of wind power plants and occurrences of important values. Challenges linked to this are particularly relevant in the investigation phase and NVE's processing of license applications. For example, we have little knowledge of both where bats are found and how wind power plants affect bats in Norway. Effects on bird migration and TV signals are other topics with great uncertainty. When such basic knowledge is lacking, impact assessments for concrete wind power projects can be both flawed and controversial. In addition to the need for new knowledge, in many cases there is also different knowledge among the various actors in the licensing process. This can lead to ambiguities and conflicts in different parts of the process, for example when it comes to assessments of noise. It also means that incomplete and incorrect knowledge can be shared.

In our consultation response to the MTA application for Bremangerlandet, we also considered a number of important areas of conflict such as bird migration etc. as the only organization to specifically address the vulnerability of bats and Norway's international responsibility to preserve species and the preservation of their habitats. Bats were not investigated at all for the wind power plant on Bremangerlandet, despite the fact that the Norwegian Environment Agency had specifically included bats as one of several weighty reasons for including Bremangerlandet as an exclusion area in the preparatory work for the National Framework for Wind Power. In addition, we have

Read the whole The Swedish Environmental Protection Agency's consultation response for Bremangerland here (PDF).

The report is a clear improvement from the current system, but much remains to be done

Now this report is very fresh today, but from what we can see there are major improvements in a number of areas which we welcome. At the same time, it is important to be aware that most of this will only apply to new wind power plants that have not yet applied for a licence. However, something will probably apply to existing licenses that will apply for changes or a construction license (MTA).

Also important to be aware of is that this has only been put forward as a proposal for measures, forwarded to the Ministry of Petroleum and Energy, where it will be possible to provide input to the report and the aforementioned input. The Swedish Environmental Protection Agency will study each point very carefully and present our views to the ministry.

Having said this, our general position on wind power has not changed. We are still clear and clear about our opposition at the same time as we work to ensure that Norway must utilize more gentle measures and energy sources before a single new wind power plant comes into question at all. This also includes all licensed wind power plants that have not been built, and also wind power plants under construction that should never have been commissioned.

It is completely unacceptable that good single-use measures, upgrades in existing hydropower plants, good gentle energy sources such as geothermal heat, fjord heat and geothermal energy production should lie as inactive tools at the bottom of the toolbox while the country is destroyed by wind power developments.

download Miljømagasinet 2019 Wind power
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The Swedish Environmental Protection Agency's 15 points for good management.

These 15 points were listed and reviewed in our consultation response to the National Framework for Wind Power. The Swedish Environmental Protection Association consultation responses can be downloaded from the Ministry of Petroleum and Energy's website here (PDF).

Premise 1 – Management

Good resource management is managing our national resources on behalf of the community and in line with the community's interests.

Premise 2 – Knowledge and competence

The administration must at all times possess the highest level of competence and knowledge within the relevant professional fields.

Premise 3 – Climate and energy

The climate problem must be solved with the best measures. A good solution cannot be burdensome for the problem it is supposed to solve.

Premise 4 – Sustainability and biodiversity

Good solutions must be sustainable and sensible, both on a national and international level.

Premise 5 – Alternative measures and sequence

A sensible and good energy policy makes use of the sources and measures which give the best return and which have the fewest negative consequences. You have to start with the best and most gentle solutions first.

Premise 6 – Legislation

A well-functioning rule of law has a well-functioning body of legislation. The laws are given to secure the community's interests. The administration itself is not above the law and must therefore comply with adopted laws.

Premise 7 – Trust

Trust is an unwritten contract between the authorities and its client, the people.

Premise 8 – Public health

Ensure everyone a good environment, good health, and promote quality of life so that everyone can live healthy and fit lives.

Premise 9 – Nature, environment and landscape

Nature, the environment and the landscape must be regarded and valued as a resource that must be secured on behalf of natural diversity, biodiversity, all residents and for future generations.

Premise 10 – The right to nature as a resource

Everyone must have equal rights to be able to harvest and utilize the common resources in such a way that they do not deprive others of the same rights.

Premise 11 – Phases in the licensing process, transparency and democracy

All resource management must follow a given set of phases where each phase contains given conditions and procedures. The population must be given insight into the criteria that are at all times the basis for the administration's weighting and decisions.

Premise 12 – Intervention and gentleness

All measures must be carried out in such a way that the negative consequences for nature, the environment, biodiversity, people and society can best be avoided or that they are as minimal as possible.

Premise 13 – Clean-up and return

No permits must be granted or measures initiated before there are good concrete solutions for environmental management and clean-up, and where the measure has a limited duration, concrete plans and solutions for a good return must also be in place.

Premise 14 – Supervision, control and follow-up

All measures must be given adequate and good follow-up through supervision and control in all necessary phases. Irregularities must have consequences, be prosecuted and brought back to an ideal state.

Premise 15 – National and international obligations

Norway is part of a global community where Norway manages resources of both national and international value. Norway is therefore obliged to follow its international agreements and conventions to which the country is a party.

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