The Swedish Environmental Protection Agency's consultation statement on Andmyran wind power

The concession area for Andmyran wind farm is to the right of the mountains in the upper part of the picture. This is Norway's largest contiguous peat bogs that Norway has an international responsibility to take care of. Photo: Arnfinn Nilsen


The Norwegian Environmental Protection Association submitted a consultation opinion on Andmyran wind power Nordland's application for deferred commissioning with the claim that this should not be accepted and that the granted license and permits must be withdrawn.

Of all licensed wind power plants, this one stands out as one of the worst socially and environmentally sound projects ever.

Firstly, the facility, including construction roads, installation sites, foundations and transformer station etc., will be built 100% in peat bog/swamp bog. The impact assessment was carried out in 2005 and a lot of new central knowledge about the value of peat bogs as CO2 stores and important habitat has been added since then. The knowledge base and policy have now been significantly changed in order to take care of the tormyren's contribution in the climate accounting. One can here, among other things, refer to The Storting's recent amendments to the Land Act (11 April 2019) to achieve the Paris Agreement's objectives.

The Storting has today adopted amendments to the Land Act to stop the new cultivation of bogs. Bogs store carbon, have a rich diversity of species and mitigate drought by storing water. Conservation of bogs is therefore an important climate and environmental issue.

- The ban on new cultivation of bogs is an effective measure that helps us fulfill Norway's climate obligations, says Climate and Environment Minister Ola Elvestuen.

As a bog area (high mire), the duck marsh is unique in both the Norwegian and Scandinavian/European contexts in terms of size, location and as a habitat for a number of important species. Intact high bogs over 50 daa are considered a priority nature type by the Directorate for Nature Management. There are no other such large contiguous coastal marsh areas anywhere else in Norway, and Norway therefore has a special national and international responsibility to secure this for existing and future generations.

The huge network of construction roads, installation sites, foundations and transformer stations etc., requires large and significant volumes of CO2-binding peat bogs dug up and removed in mass replacements. In addition, both construction activities and the filling materials will entail a great and imminent danger of puncturing the aurhelle (gravel crust) which is located under the bog. A puncture of this can result in a lowering of the groundwater table and drainage of the area. The consequences of this will be fatal and in addition to the consequences this will have for the marsh's function as a biotope, this will further contribute to a significant negative climate account.

Andøya has a rich bird life with, among other things, a large population of sea eagles, whooper swans and large gatherings in connection with the autumn and spring migration. The bird records that have been made are both deficient and incomplete. Here, they have largely only been inside during the day during the breeding season, while the entire autumn migration, the winter months and early spring have not been mapped. This wind power plant will be located in the middle of the migration route during the autumn and spring migration and there are large numbers of geese and other bird species that use this corridor as a migration route and resting places. One also refers here to the Bern Convention and to the Hague/Agreement on the protection of African-Eurasian migratory waterbirds, where Norway has a particular responsibility for looking after a number of migratory birds native to Norway and securing their breeding areas and migration routes.

In terms of landscape, it is natural to draw lessons from the wind power plant at Smøla, which is also characterized by large low-lying areas by the sea. The experience here shows that a significant number of birds are killed throughout the year (including the breeding season), and like Smøla, Andøya also has a significant population of sea eagles which will be particularly exposed to collisions with rotating turbine blades. What is not revealed in the registrations is that in the shallow bays on the north-eastern parts of Andøya, where Andmyran wind power is located, there are occasionally larger gatherings of sea eagles in the late winter/early spring period.

The entire area from the Andenes in the north on the east side of the mountains and all the way to the south of the island is flat moorland. This means that the wind turbines will be highly visible far beyond what is outlined in visibility maps and visualisations. In the winter months, the turbines' reflex flashes will be a nuisance and cause visual pollution to large parts of the eastern side of the island. It should be noted here that Andøya has been severely affected in recent years by the closure of Andøya military airport, which will have major negative societal consequences and ripple effects. The other major business route and source of income for this community is linked to tourism. Tourism here is mainly linked to nature tourism, where there is a lot of activity around whale watching combined with nature and landscape all year round. In the winter months, it is also largely based on northern lights tourism, where there are a large number of visitors from all over the world. There is no doubt about what tourism as a whole means for this small, vulnerable community. Andmyran wind power plant will pose a direct threat to this important business route and to this society as a whole. Reflex flashes and visual pollution are not compatible with tourism where the experience of nature and magnificent landscapes is the focus.

Overall, this facility will produce a particularly poor climate report, provide negative social benefits and significant negative consequences.

The Norwegian Environmental Protection Association therefore advises against extending the deadline and also requests that the granted license and permits be withdrawn.

Read the full consultation statement here.

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