WPD Mangsliberget Wind Turbine Industrial Project - Consultation
WPD is exploring the possibility of constructing a large wind turbine industrial power project with a maximum of 34 wind turbines of 3 to 5 MW with a total height of 250m in the area around Mangslidberget in Torsby municipality, Värmland Province. The project area is located about 20 km west of Ambjörby and Likenäs and about 40 km north of Torsby. The land is mainly owned by Bergvik forest and by some private landowners, and the area is partly characterized by modern forestry.
Image of a footprint for a single turbine comparable to what is planned for Mangsliberget.
The project is run by a project company that is part of the wpd group and is owned by wpd europe GmbH. The development work is conducted through wpd Scandinavia AB, also a subsidiary of wpd europe GmbH. Wpd in Sweden is currently working on the design and development of a number of wind power projects, including the land-based projects Aldermyrberget, Broboberget, Lannaberget, Stöllsäterberget, Råliden and Tomasliden, as well as the offshore project Storgrundet.
Expected example of typical visibility of a turbine at Mangsliberget.
WPD intends to apply for permit under the Environmental Code for the wind farm with associated roads and electrical equipment at the Environmental Testing Delegation (MPD) in Örebro County, which handles permit issues located in Värmland County. WPD refers to seeking permission to establish the wind farm within a specified project area but without fixed coordinates for the wind power plants. The document Vindkraftspark Mangslid - Samrådshandling (Wind farm Mangslid - consultation document) forms a basis for consultation and describes the project at an early stage. 1
1 http://www.wpd-sweden.com/fileadmin/pdfs/Mangslid/2017-10-18-
2 WPD conducts consultations for this project under the Environmental Code, the “Ellagen” and the Cultural Heritage Act. The consultation document has been prepared in accordance with the rules for consultation prior to the license application under Chapter 6. Section 4 Environmental Code. The permit application with the accompanying environmental impact assessment (SME) is designed inter alia based on what appears during consultation, and is supplemented by, among other things, in-depth descriptions and results from supplementary field studies and inventories. This consultation paper provides information on the planned wind farm location, scope, design and expected environmental impact that has so far been foreseen.
MANGSLIBERGET, FINNSKOGEN
Mangsliberget - a 7 km long 580 meter high ridge of pristine natural habitat of forests and marsh located is in the heart of the Norwegian Swedish border area known as Finnskogen .
1. Nature and Cultural Park
Finnskogen has been designated as one of the important areas for nature and cultural conservation and is now known as the Finnskogen Nature and Cultural Park (www.finnskogen.org). This is a cooperation between three Norwegian counties (Grue, Åsnes and Kongsvinger) and one Swedish county (Torsby) for promoting natural conservation and the development of sustainable eco and cultural tourism reflecting
3 Finnskogen’s combination of rich and diverse wildlife and cultural heritage from where it derived its name. The ultimate goal is to have Finnskogen designated as a UNESCO Heritage Site (see below).
2. Finnskogen’s Vernacular Heritage
Finnskogen has been the target of many studies for more than a hundred years because of its exceptional history, vernacular heritage and traditions that can be traced back to the origin of the settlers from Finland Vernacular building is a way of expression that carries messages from one generation to another and a message of belonging to a culture. When people are moving to other places how does the vernacular expression answer to the new circumstances? Built vernacular heritage is normally based on long traditions of the use of local materials and of their gradual refining processes. Are global markets a threat to the vernacular expression?
3. Tourism Destination
Finnskogen has been named the second go to destination in 2018 by the influential Norwegian National Newspaper Aftenposten. With its unique history, vast forests and a wide array of activities makes Finnskogen a destination of choice for nature lovers, says travel editor Marie Peyre in the Local. 2 Finnskogen is an important area to be included in the new Guided Trail Based Eco and Adventure Tourism Product by Visit Värmland. A systematic plan to reach the greater European continental market, the UK and, most signicantly the greater Asian and China markets is now underway.
4. New Settler Destination and Future Demographics
Finnskogen was in its prime a rich area with several 1000 inhabitants. At the turn of the 18th to 19th century Nyskoga alone had some 800 inhabitants. The population has over the last 50 years been in continuing decline but has lately been receiving permanent settlers form urban areas of Scandinavia and greater continental Europe which has kept the population of Finnskogen relatively stable. In 2015 the registered population of greater Finnskogen was 593 (Finnskogen North and Finnskogen South) with some 557 inhabitants registered in 2017. With the current trends it is projected that by 2025 the Finnskogen will have some 446 inhabitants3. This projection does not take into account the potential for further increased interest from continental Europe or even afar or possible investments into diverse new business activities of which the most promising is Eco and Trail based tourism
2 https://www.thelocal.no/tag/finnskogen 3https://www.torsby.se/download/18.53c3f6ab160d5325cf2cd138/1516094861117/Befolkni ngsprognos%20delområden%20Torsby%202016-2025.pdf
4
Letter from Finnskogen Anno 2018! Come and help on our farm in the swedish
Finnskogen https://www.workaway.info/231984957939-en.html
Our dream: simply good living!
Since 2013 we live and work on our farm in beautiful Värmland, in the borderregion between Sweden and Norway. But not only the impressing location on the edge of Finnskogen brought us here, rather our farm is a lifelong self- sustainability-experiment for us!
We want to live in and with the nature around us and we want to feel the earth beneath our feet. Here a permaculture-project with animal keeping will be created in the coming few years on approximately 10 acres. The nearby 20-acres forest gives us enough wood for keeping the house warm in winter in a sustainable way and also enough to produce some building material.
The Kymsälven flowing over the plot also creates possibilities for the use of renewable energy.
Who are we
Currently we live as a 3-person-family permanently here on the farm and welcome guests and interested people who want to live and work with us for a few days or for a longer period of time. In addition to our self-sufficiency project we ( Laura 34 , Mark 37) work here as social workers and systemic coaches. Our daughter Nele (3) visits the Swedish kindergarten.
We are from Germany and live here since 2013. We speak German ,Swedish, English and a little Spanish and French.
5
Finnskogen and the EU Leader Program for Local Development
Mangsliberget Finnskogen is located in the heart of Inner Scandinavian Heartland and the EU Strategic Cross-Border Programme called INTERREG as part of the EU Leader Programme. The programme includes Värmland and Hedmark Provinces. Torsby Kommune has been an active participant in this programme.4
The program main strategy is applying the “bottom-up approach” which means that local actors participate in decision-making about the strategy and in the selection of the priorities to be pursued in their local area. Of the seven features of Leader the most distinctive one is the bottom-up approach. Rural policies following this approach should be designed and implemented in the way best adapted to the needs of the communities they serve. One way to ensure this is to invite local stakeholders to take the lead and participate. This holds true in both the EU of 15 and of 25 Member States, but is equally important in countries aspiring to EU membership where there are structural problems in agriculture and many opportunities to improve the quality of rural life. 5
The involvement of local actors includes the population at large, economic and social interest groups and representative public and private institutions. Capacity building is an essential component of the bottom-up approach, involving: awareness raising, training, participation and mobilisation of the local population to identify the strengths and weakness of the area (analysis);
• participation of different interest groups in drawing up a local development strategy; • establishment of clear criteria for selection at local level of appropriate actions (projects) to deliver the strategy.
Participation should not be limited to the initial phase but should extend throughout the implementation process, contributing to the strategy, the accomplishment of the selected projects and in stocktaking and learning for the future. There are also important issues of transparency which need to be addressed in the mobilization and consultation procedures in order to reach consensus through dialogue and negotiation among participating actors.
4 https://interreg.no/prosjektbank/scandinavian-heartland-business-improvement/
5 https://www.pobal.ie/FundingProgrammes/LEADER/Pages/LEADER.aspx
6 Our Comments as part of the consultation process on the possible impact of the proposed wpd Mangsliberget Wind Turbine Industrial Project
A Swedish EPA (Naturvårdsverket) Notification to Norway EPA (Miljødirektoratet) in accordance with the ECE Convention on Environmental Impact Assessment in a Transboundary Context (Esbo Convention) on plans for the wind farm Mangslid in Torsby municipality states: 6
“The wind farm has a size which is ….. considered to have significant environmental impact …..and … The planned operations are expected to have significant environmental impacts in Norway as planned near the border between Sweden and Norway”
The following are some of the grave and serious real concerns for the Industrial Wind Turbine Mangsliberget Proposed 32 - 3 to 5 MW Wind Turbine Project:
• Severe and irreparable damage to Mangsliberget - a pristine marsh area with rich birdlife including many owl types, hawks, falcons, eagles, and other threatened species. The variety of birdlife should qualify Finnskogen to be included under the EU Birds and Habitat Directives of NATURA 2000. 7
• High risk of exposing those who use Mangsliberget and surrounding area for recreational purposes in wintertime to real and lethal dangers of ice thrown out from wind turbine blades at great speed (see below). 8
• Lethal danger to birds due to direct collisions with turbine blades that have a speed on downward stroke of 300 km/h. Mangsliberget is in the middle of the path of migratory birds. 9
• There is strong anecdotal evidence10 that turbines impact individual health in those living within about 1 to 2 km of current wind turbine plants as local population will experience the “wooshing” noises year- round, year after year.
6 http://www.miljodirektoratet.no/Global/dokumenter/horinger/Grensekryssende/Underrättelse %20t%20Norge,%20Mangslid%20vindpark%20171020.pdf?epslanguage=no
7 http://ec.europa.eu/environment/nature/natura2000/index_en.htm https://www.birdlife.org/europe-and-central-asia/birds-and-habitats-directives
8 https://munin.uit.no/bitstream/handle/10037/9750/article.pdf?sequence=2 http://orbit.dtu.dk/files/103715241/Adri_na_Hudecz_Afhandling.pdf
9 https://abcbirds.org/wind-energy-threatens-birds/
10 http://www.theenergycollective.com/willem-post/2395070/wind-turbine-noise-adversely- impacts-nearby-people-and-animals
7
• Those nearby people would be impacted through
- Decreasing property values.
- Impacted their health, due to lack of sleep and peace of mind
- Living with closed windows and doors, due to year-round noises.
- Constant Shadow flickers
• For the proposed project there is to our knowledge no available documentation on the possible impact for surrounding area from comparable sites in relation to distance, quality and quantity of noise pollution for such large turbines of 3 to 5 MW.
• The Impacts of Infra and low frequency noise waves on wildlife of 3 to 5 MW turbines is as yet undetermined.
• In addition the quantity of Shadow Flickers being created by these large turbines is in relation to quality and quantity needs to be explored.
• The negative impact on tourism industry of the greater area where visibility of 250 meter high turbines on a 580 meter high range will cover a very great border area of Norway and Sweden.
• Compromise the ongoing plans for intensifying development of recreational and ecotourism. Eco and guide led tourism (Paddling, hiking and bicycling) being developed by Visit Värmland as a unique tourism product will undoubtedly be severely compromised for the Finnskogen area if a large wind turbine industrial power project became a reality.
• Compromise any planned further development of Finnskogen as an attractive area for primary and secondary habitat.
• May compromise ongoing work to have Finnskogen designated as a UNESCO heritage site.
8 ATTENTION! Lethal Dangers from Ice Blocks Thrown from Large Wind Turbines in Colder Climates.
This phenomenon is extremely dangerous for persons that find themselves in the vicinity of large industrial wind turbines. Icing happens on moving blades. When formed, it holds fast on the surface regardless of the inertia of the blade movement. It is reported that when the turbine is stopped and turned back on, there is a higher rate of ice throwing.
Wind turbine operating in cloud and cold climates with ice formation http://orbit.dtu.dk/files/103715241/Adri_na_Hudecz_Afhandling.pdf
Ice Throw from Wind turbines https://munin.uit.no/bitstream/handle/10037/9750/article.pdf?sequence=2
9 IV. Conclusion
A large wind turbine industrial power project at Mangsliberget flies in the face and makes a mockery of the ongoing INTERREG EU Leader Project which is founded on a local bottom-up initiated approach. The Mangsliberget Wind Turbine Industrial Power Project Proposal is initiated and driven by external forces in stark contrast to the Leader locally initiated bottom-up approach for development of rural areas in the EU.
It is difficult to see any positive ramifications for the Finnskogen communities or to those who use this area for recreational purposes in either the short, medium or long term. This project risks to undermine the ongoing efforts promoting new settlers to the area and for development of Ecotourism and Guide Based trail tourism both of which will undoubtedly be severely compromised,
Any gains sought for the contribution to alternative energy production -which for wind is highly subsidized and tariff driven and of very temporary nature with maximum lifespan of only 25 years as concluded in the letter from the swedish EPA Naturvårdsverket to the norwegian EPA Miljødirektoratet. - must be weighted up against the unquestionable irreparable and irreversible environmental destruction of sensitive areas as is Finnskogen .
Sweden and its neighbor Norway must focus on rational development of alternative minimal invasive clean energy (e.g. water and solar) coupled with much greater focus on energy conservation.
Prepared by: Torkel Snellingen MD, PhD (dr Med), MPH, DCEH (London) Professor , Lecturer and Academic Reviewer of Clinical Epidemiology and Evidence Based Public and Administrative Health Policy
[email protected] Tel +4741567612
Lu Yao Torkel Snellingen Lustgården Nyskoga 68594 Torsby Kommune
10