The Swedish Environmental Protection Agency's consultation response to Havvind

The Swedish Environmental Protection Agency delivered consultation response on the government's hearing - "Hearing of proposals on the opening of areas for renewable energy at sea and proposals for regulations for the Ocean Energy Act".

The Norwegian Environmental Protection Association looks with concern at the uncritical investment in offshore wind and the potentially large negative environmental consequences this entails. These are large constructions that will be placed in vulnerable marine ecosystems. We humans depend to the very highest degree on the sea and that it is managed in a future-oriented and sustainable way. Offshore wind is not the solution, and the proposed developments may actually prove to cause irreparable damage to the marine ecosystems. We cannot afford to gamble with this. It is, after all, our most important dinner plate, and hence also central to our own existence and survival.

The Environmental Protection Association demands that the three selected areas be withdrawn and exempted from development. Furthermore, we recommend that more funds must be allocated for research into environmental consequences within a number of fields that have not yet been investigated or that have been inadequately investigated, and that further investment in offshore wind be put on hold until it can be documented that such development is not harmful to the marine ecosystems. We are definitely not there today, and our recommendation is therefore an immediate and full "Timeout" for all further investment in offshore wind.

The designated areas

In this consultation statement, three areas have been identified, two of which are located just offshore on the coast of North Rogaland and just off Sørøya in Finnmark. The last area is in the very south of the North Sea.

Utsira North

The Utsira Nord area lies in coastal waters west of Haugalandet in northern parts of Rogaland, and stretches in a north-south direction from the Bømlafjorden to the Boknafjorden.

Sandskallen-Sørøya Nord

The Sandskallen-Sørøya Nord area is located in coastal waters in the Barents Sea northwest of Hammerfest.

Southern North Sea II

The Southern North Sea II area is the furthest south in the North Sea.

Where is the social benefit?

  • Climate-wise there is no or questionable climate benefit. Where is the social benefit?
  • Economic nor is there any gain when practically the entire project has to be subsidized with community funds. No social benefit here either.
  • Technological nor do we get any significant advantage with something that others can also quickly do both better and cheaper. Social benefit? Blown away with the wind and the subsidy kroner?
  • Administratively is giving preference to narrow interests to the exclusion of the community a bad model. Here, there will be negative consequences for everything from the fishing industry, ecotourism, outdoor recreation and more nature-based industries.
  • Environmentally is full of problems and areas of conflict. Birds, large marine mammals including several vulnerable cetacean species, fish and their important spawning areas, and a number of other environmental consequences. Absolutely no social benefit here either.


There will be significant environmental consequences associated with the development of offshore wind. This is mainly due to direct pollution with oil and chemicals, large amounts of noise and low-frequency infrasound in the marine environment, electromagnetic disturbances to fish's navigation system, and to the risk of collisions for seabirds and migratory birds. One would like to note here that there is a lack of knowledge in several important subject areas, but what is known gives great cause for concern. In fact, several of the environmental consequences are so great and serious that the development of offshore wind is strongly discouraged.

  • Offshore wind costs far too much greenhouse gas emissions in the extraction of materials, production, shipping, assembly, operation, service and maintenance, decommissioning and recycling of materials so that this gives a good climate account. Offshore wind is and will be a pure climate burden.
  • Increased risk of collision for shipping offences, oil spill.
  • Acute contamination risk in case of leakage of hydraulic and transmission oil.
  • Oil spill documented more dangerous than previously thought.
  • Great source for contamination by microplastics in the sea due to wear and tear of turbine blades.
  • Large networks of submarine cables provide electromagnetic fields, harmful to several species.
  • It the European eel is critically endangered - Offshore wind can make the situation even more critical.
  • The offshore wind fields in conflict with eel migration routes.
  • The eel is dependent on electromagnetic signals from the earth to find the way to and from the spawning grounds in the Sargasso Sea.
  • Changed sediment conditions for sea wind on sand and mud bottoms.
  • Broad-spectrum and low-frequency noise harmful for marine mammals, fish and other life.
  • Also Fish communicate with sound - uses sound to courtize during spawning - critical due to noise.
  • Decline for coastal and fjord cod - Sea wind will make the situation even worse.
  • Insufficient impact assessments for fish, fishing behavior and for important spawning areas.
  • Spawning and the habitats of tobis in the southern North Sea is incompatible with the environmental impacts of sea wind; noise and electromagnetic.
  • Norwegian spring-spawning herring are threatened by sea winds.
  • Birds and bird migration – Damage to migratory birds and seabirds – Important bird migrations.
  • Visual pollution for two of the facilities that will remain in the middle of the coastline just offshoreStrong reflex flashes in the evening and at nightIncompatible with outdoor life, ecotourism and other nature-based businesses.
  • Sea wind incompatible with The UN's Sustainable Development Goals.
  • The precautionary principle must apply, substantial research basis is lacking.

The OED is already aware of the consequences of electromagnetic fields' influence on marine species..!!!

On 31 August 2010, the Ministry of Petroleum and Energy appointed an expert committee to investigate technology, economics and other matters relating to a submarine cable solution in Hardanger. The committee hereby submits its report. All of the committee's recommendations are unanimous.

The expert committee's report to OED from the Sjøkabelutredningen, 2011 (PDF)

Particularly valuable areas

In the management plan for the North Sea and Skagerrak (Meld. St. 37 (2012-2013)) there is area within the relevant areas that has status as a particularly valuable area. These areas are important for biological production and for biological diversity.


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