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Enclosure 1

Background information  - Short excerpts from recent reports to the Storting containing national objectives and policy. Short information about the Smøla project.
Report to the Storting No 29 (1998-99) Om energipolitikken (About the energy policy)
The Government will prepare for an energy policy that supports an ambitious environmental policy.
The Government?s energy policy is developed on the assumption that national objectives will determine the production possibilities, and that it is necessary to carry an active policy in order to limit consumption.
In the next years the Government would like to encourage the development of renewable energy sources through an extensive development programme. The objective is that wind power production of 3 TWh/year is built by 2010. (page 6)
Regjeringen legger opp til en energipolitikk som underbygger en ambisiøs miljøpolitikk.
Regjeringens energipolitikk bygger på at miljømålene vil bestemme produksjonsmulighetene, og at det er nødvendig å føre en aktiv politikk for å begrense forbruket.
I de nærmeste årene vil regjeringen stimulere til å utvikle fornybare energikilder gjennom et omfattende utviklingsprogram. Målet er en utbygging av vindkraft på 3 TWh/år innen 2010. (side 6)
The choice between the various concrete solutions must be done at the local level. The role of central authorities must be to point out the direction for development and stimulate to a change of direction on a broad basis. (page 32)
Valget mellom de ulike konkrete løsninger må gjøres lokalt. Sentrale myndigheters rolle må være å angi retningen for utviklingen og stimulere til en omlegging på bred basis. (side 32)
Report to the Storting No 58 (1996-97) Miljøvernpolitikk for en bærekraftig utvikling (Environmental policy for sustainable development).
The Government  will give high priority to the work of conserving our biological diversity, by focussing on the causes for loss of diversity, by securing sustainable use of biological diversity and by protecting endangered diversity
The sectors and the municipalities must as far as possible avoid encroahments into the remaining, continuous wilderness areas and other valuable nature types that are mentioned in this report (page 15).
Regjeringen vil gi høy prioritet til arbeidet med å bevare det biologiske mangfoldet, ved å rette fokus mot årsakene til tap av mangfold, ved å sikre bærekraftig bruk av biologisk mangfold  og ved å verne truet mangfold.
Sektorene og kommunene må så langt som mulig unngå inngrep i de gjenværende, sammenhengende urørte naturområdene og andre verdifulle naturtyper som er angitt i meldingen. (side 15).
Box 5.2 Areas that are especially important in order to conserve biological diversity.
Nature areas and ecosystems are especially important if they:
a) are large continuous nature areas that are virtually not affected by technical encroachments
b) belong to the group of vulnerable nature types confer chapter 11.3.9
c) are rare or unique and/or of special value in a Nordic or international perspective and is especially representative for the biological diversity of Norway
d) have special ecological or biological functions, e.g. areas that are important for reproduction, migration and water household
e) are breeding grounds or in other ways of special importance for endangered, vulnerable or economically important species and populations.) (page 50)
Boks 5.2 Områder som er særlig viktige for å bevare biologisk mangfold
Naturområder og økosystemer vil være særlig verdifulle om de:
a) er store sammenhengende naturområder som er tilnærmet uberørt av tekniske inngrep
b) tilhører gruppen av hensynskrevende naturtyper jf kap 11.3.9
c) er sjeldne eller unike og/eller har særlig verdi sett i nordisk eller i internasjonal sammenheng eller er særlig representativ for det biologiske mangfoldet i Norge
d) har spesielle økologiske eller biologiske funksjoner, bl a områder som er viktige for reproduksjon, vandringer og vannhushold
e) er leveområder eller på annen måte av særlig betydning for truede, sårbare, sjeldne eller økonomisk viktige arter og bestander (side 50)
Report to the Storting  No 24 (2000-2001) Regjeringens miljøvernpolitikk og rikets miljøtilstand  (The Government?s environmental policy and the country?s environmental status).
The Government will through this report to the Storting accentuate the ecological perspective as a basis for policy formation in all sectors of society. (page 9)
Regjeringen vil med meldingen om Rikets miljøtilstand vektlegge det økologiske perspektivet som grunnlag for politikkutformingen på alle områder i samfunnet. (side 9).
Strategic objective for the conservation of biological diversity
Our nature shall be managed in such a way that species that are native are secured in viable populations, and that the variety of nature types and populations are maintained  and which makes it possible to safeguard continued possibilities for development of the biological diversity. (page 23)
Strategisk mål for bevaring av biologisk mangfold:
Naturen skal forvaltes slik at arter som finnes naturlig sikres i levedyktige bestander, og slik at variasjonen av naturtyper og bestander opprettholdes og gjør det mulig å sikre det biologiske mangfoldets fortsatte utviklingsmuligheter. (side 23)
National objectives
1. A representative selection of Norwegian nature shall be protected for the benefit of future generations
5. Endangered species shall be maintained or be restored to viable levels. (page 23)
Nasjonale resultatmål
1. Et representativt utvalg av norsk natur skal vernes for kommende generasjoner
6. Truede arter skal opprettholdes på eller gjenoppbygges til livskraftige nivåer. (side 23)
A systematic mapping of wilderness areas have been carried out during later years that is areas that are located more than one kilometre (air-line) from large technical encroahments.
Wilderness areas are of great importance to open-air recreation and nature experiences, but also important for biological diversity
In this connection tractor roads, forestry roads, power lines and energy developments represent the largest and most numerous encroachments. In order to conserve as much as possible of the remaining wilderness areas, the individual sector and municipality in question must, to the extent possible, avoid further encroachments into such areas.) (page 25)
Det er de senere årene foretatt en systematisk kartlegging av inngrepsfrie områder - det vil si områder som ligger lenger unna enn en kilometer i luftlinje fra tyngre, tekniske inngrep.
Inngrepsfrie områder har stor betydning for friluftsliv og naturopplevelse, men er også viktige for biologisk mangfold.
Traktorveger, skogsbilveger, kraftlinjer og kraftutbygging representerer i denne forbindelse de største og fleste inngrepene. For å bevare mest mulig av de gjenværende inngrepsfrie områdene, må den enkelte sektor og kommune så langt som mulig unngå ytterligere inngrep i slike områder. (side 25)
Report to the Storting No 42 (2000-2001) Biologisk mangfold - sektoransvar og samordning (Biological diversity sectorial responsibility and coordination)
The report is a political tool for Norway?s implementation of the convention on biological diversity. Sectorial responsibility and coordination has been tied directly to Article 6 in the convention, where all sectors are supposed to take the responsibility of integrating biodiversity considerations in their management. (page 9).
Meldingen er et politisk verktøy for Norges oppfølging av konvensjonen om biologisk mangfold. Sektoransvar og samordning er knyttet direkte til artikkel 6 i konvensjonen, der alle sektorer skal ta ansvar for å integrere hensynet til biologisk mangfold  i sin forvaltning. (side 9)
Strategic objectives for the conservation of biological diversity
Our nature shall be managed in such a way that native species are secured in viable populations, and in such a way that the variety of nature types and populations are maintained and which makes it possible to safeguard biological diversity its continued possibilities for development. (page 20)
Strategisk mål for bevaring av biologisk mangfold:
Naturen skal forvaltes slik at arter som finnes naturlig sikres i levedyktige bestander, og slik at variasjonen av naturtyper og bestander opprettholdes og gjør det mulig å sikre det biologiske mangfoldets fortsatte utviklingsmuligheter. (side 20)
Strategy
1. The causes for loss of biodiversity must be addressed
The most important direct causes are habitat destruction, overexploitation of biological resources, pollution and introduction of alien species. These direct causes are rooted in underlying causes or pressures from society. (page 20)
Strategi
1. Årsakene til tap av biologisk mangfold må angripes
De viktigste direkte årsakene er arealinngrep, overbeskatning av biologiske ressurser, forurensning og spredning av fremmede arter. Disse direkte årsakene har sin rot i underliggende årsaker eller drivkrefter i samfunnet. (side 20)
An important precondition in order to maintain diversity and secure sustainable use is based on the assumption that all stakeholders and sectorial authorities implement the national objectives that have been set, confer chapter 2.1. It is also important that the follow-up is differentiated so that nature areas of special value and ecosystems are prioritised. These are large continuous nature areas that are:
1. only to a minor extent affected by encroachments
2. endangered or vulnerable nature types
1. rare, unique or have sepecial ecological and biological functions
2. habitats for endangered, vulnerable or ecologically important  species and populations. (page 37)
En sentral forutsetning  for å opprettholde mangfoldet og sikre bærekraftig bruk ligger i at alle aktører og sektormyndigheter følger opp de nasjonale resultatmålene som er fastsatt, jf kap 2.1. Det er også viktig at oppfølgingen differensieres slik at særlig verdifulle naturområder og økosystemer prioriteres. Dette er store sammenhengende naturområder som er:
1. Lite berørt av inngrep
2. Truede og hensynskrevende naturtyper.
4. Sjeldne, unike eller har spesielle økologiske eller biologiske funksjoner.
5. Leveområder for truede, sårbare, sjeldne eller økologisk viktige arter og bestander. (side 37)
Status and trends for wind power production
The effects of windfarms on breeding, resting and foraging birds have not been investigated in Norway, or in countries with a comparable ecosystem structure. (page 163)
Status og utviklingstrekk for vindkraft
Innvirkning fra vindkraftverk på hekkebestander, rastende og beitende fugl er ikke systematisk undersøkt i Norge, eller i land med sammenlignbar natur. (side 163)
Evaluation of incentive measures for windpower production
Incentive measures in order to reduce the negative effects of windfarms are primarily to locate the windfarms in areas where the effects on biological diversity are acceptable.
In connection with granting licences there are requirements of carrying out pre-development environmental investigations as basis for investigations that are to be carried out for some years after the establishement. (page 168)
Vurdering av virkemidler for vindkraft
Virkemidlet for å redusere negative virkninger av vindkraft er i første rekke å lokalisere vindparker til områder med akseptable virkninger for biologisk mangfold.
I forbindelse med konsesjonstildeling er det satt vilkår om å utføre forundersøkelser som basis for undersøkelser over noen år etter utbygging. (side 168)
Planning processes at Smøla the Smøla project
Large areas at Smøla island have proved to be valuable in connection with several conservation plans; conservation plan for birds, conservation plan for wetlands, conservation plan for mires and mapping of cultural landscapes of special value. There were many ovelapping conservation interests, and at the same time an opinion that the conflict level was low. Against this background Smøla was removed from the various conservation plans in order for a total conservation plan for the island to be developed. This plan is now under development by the County Governor of Møre and Romsdal, but we do not foresee that the whole plan will in effect until 2003.
The Smøla project
During spring 1998 the Smøla municipality initiated the establishment of a project that was to coordinate the various planning processes in relation to each other. This included NVE?s management procedures related to notification, applications and EIAaccording to the Energy Act and regulations related to environmental impact assessments, the establishment of a municipal master plan for windpower and local development plans and the County Governor?s work with protected area planning for Smøla island. Representatives for the various authorities have participated in the project group. Part of the project has been financed by the Ministry of the Environment.
The results from the Smøla project is thought to be a municipal master plan for windpower production according to the Planning and Building Act and a conservation plan according to the Nature Conservation Act:
* The municipal master plan for windpower production was decided on by Smøla municipal board on 27 March 2001 after a mediation process that limited the proposed area plan.
* A conservation plan according to the Nature Conservation Act is expected to be in force by 2003.

Enclosure 2

Comments to the Statkraft SF: Notification about windfarm at Smøla in Møre and Romsdal
County from the Directorate for Nature Management (DN) 2 March 98 (Excerpts from letter)
In general the Directorate for Nature Management (DN) is positive to the idea that development of windfarms now seems to be realised in Norway.A cost / benefit analysis for the establishment of windfarms should nevertheless be based on a realistic picture of the potential for using wind energy along the coast together with the effects on nature and the landscape that such encroachments can imply.
It is important that a process is carried out that actively secures coordination between the procedures according to the Planning and Building Act and the licence procedures according the Energy Act on the one hand, and the work with a municipal master plan and a conservation plan on the other.
Our comments for the commissioned reports about questions that have to be elucidated and discussed entail themes like landscape, open-air recreation, biological diversity, noise/disturbances, alternative uses of areas, effects of necessary infrastructure, conditions friendly to children and youths, mitigating measures and measures taken to reduce conflicts.
In order to elucidate the relevant questions and thereby obtain a satisfactory basis for decision, the applicant must as soon as possible during this spring start investigations in order to obtain information about migration patterns and abundances for birds and habitats for breeding birds in the area.
Loss of biological diversity was defined by the World Commission as a global environmental threat together with climate change, radioactive waste and so on. The most important threat to biological diverstiy in the terrestrial environments is that habitats are split up or are lost.
Consequently, DN would like to signal that one needs to be restrictive with respect to the establishment of such constructions when the areas contain especially important biological diversity or have an important ecological function. Examples of this can be resting areas for waterfowl or areas that are part of migration routes for the various bird species.

Enclosure 3

Comments to Application for licence according to the Energy Act and an evaluation of environmental impact assesments Statkraft and NEAS  by the County Governor of Møre and Romsdal 1 May 00 (Excerpts from the letter).
Abstract:
The County Governor advises against NVE granting licence according to the Energy Act for a windfarm of 40 MW for NEAS and for a full-scale development according to step II for Statkraft (150 MW). According to an overall evaluation the County Governor is ready to accept a development as applied for by Statkraft, for a windfarm of 20 wind mills with an effect of 40 MW (step I). The precondition for such advise is that the entry road to the park is built from the south, and that the power line is grounded by cable from the transformer station inside the park and further along the road past the Hinnå River. No proposal for a follow-up programme for effects on common interests has been put forward. We assume that such programme will be forwarded to us for comments, and that an eventual licence contains the necessary conditions for such investigations.

Enclosure 4

DN?s comments to Statkraft  SF; Environmental impact assessment (EIA) and application for licence of windfarms at Smøla in Møre and Romsdal County, 18 May 2000 (Excerpts from the letter).
In general DN is positive to the idea that development of windfarms now seems to find its realisation as an alternative energy source in Norway. A cost / benefit analysis for the establishment of windfarms should nevertheless be based on a realistic picture of the potential for using wind energy along the coast and also considering the effects on nature and the landscape that such encroachments can imply.
The requirements of the EIA programme have not been satisfactorily met in some respects, this concerns consequences for birdlife and follow-up investigations in general. In the EIA it has been concluded that the development of Step I (40 MW) would to some extent lower the level of conflicts because the areas involved are smaller and the windfarm will be less dominant in the landscape than a full development of Step I + II (150 MW).
DN is of the opinion that from an energy policy point of view it is right to develop new forms of energy. At the same time we would like to stress that in this project there are considerable uncertainties as to the extent of effects for nationally important environmental values. An essential precondition related to our recommendation to build Step I is consequently that the permission of the licence contains requirements for follow-up investigations.  Especially now at the outset of building windfarms in Norway, large windfarm projects must in general evolve in such a way that the development takes place in steps. When the environmental effects of the preceding step have been satisfactorily investigated and evaluated, following steps may eventually be permitted. Consequently DN advises against giving permission for a full development (Step I +II). We could accept a development, as applied for by Statkraft, that implies a windfarm of 20 wind mills producing an effect of 40 MW (step I).
A precondition for the permit is that the entry road for the windfarm is built from the south, and that the power line is grounded by cable from the transformer station inside the park and continues along the road past the Hinnå River.
Statkraft has not put forward a programme for follow-up investigations and a plan for how these should be carried out, cf point 11 in the established EIA programme. In the case that a licence is granted, conditions need to be made for which investigations should be carried out and for a deadline for such investigations to take place. We assume that a proposal for such a programme for follow-up investigations will be sent on a public hearing.
We consider the duty of investigation fulfilled granted that the matters stated above are included in the conditions for granting licence.

Enclosure 5

DN?s comments to Windpower production at Smøla - additional information from
Statkraft, 24 November 2000 (Excerpts from the letter).
DN maintains its recommendation that Statkraft can be granted licence for of up to 40 MW
(Step I). DN further recommends that licence is not given to NEAS. DN considers it a precondition that before eventual further development of windfarming at Smøla more investigations should take place in order to document the effects of an eventual windfarm, especially in relation to ornithological interests. DN?s recommendation is limited to building step I. DN will in case of an eventual further development evaluate the measures proposed anew, among other things from the most recent information available.
Primarily DN recommends that the high voltage power line towards Straumen is grounded by cable from the transformer station to the Hinnå River. Gounding by cable is the only measure that definitely will minimise conflicts with ornithological interests. Cabling will also reduce the conflicts with landscape interests to a considerable extent. On stretches where cabling is not perceived (or planned for) it is a precondition that power lines are established that as much as possible concentrate the encroachments and as well minimise as much as possible the danger of collisions for birds, both by choice of  power line type and by special marking of the power lines in areas where the risk of collisions is especially high.
In its comments to the public hearing DN made it a prerequisite that entry to the transformer station and the windfarm for Statkraft?s building step I should be established from the south. Changing the entry would lead to less conflicts with wildlife interests and improve the availability of cabling of the power lines from the transformer station to the Hinnå river. DN understands that there are technical and practical reasons for the chosen positioning of entry. The most important argument for us, however, is that the power line is grounded by cable.
In parallell with the applications for licences Smøla municipality has suggested a municipal master plan for windframs and a local development plan for Statkraft?s development plan, step I..
From a general point of view DN has signalled a positive attitude towards the development of windfarms. For the projects at Smøla island this has been expressed through the fact that DN has recommended building step I can be carried out even though a considerable potential for conflicts exists in relation to for example birdlife, conservation of wilderness areas and the considerations for a characteristic nature and cultural landscape. A precondition for DN?s positive attitude towards Statkraft?s application is that a thorough evaluation of the consequences of this project is carried out before an eventual consideration of building more windfarms at Smøla. DN?s recommendation of building step I should  not give any basis for expecting that DN without question will recommend further establishments at Smøla in the future.

Enclosure 6

Norwegian Water Resources and Energy Directorate (NVE) grants licence to
Statkraft, and denies licence to Ørntua and NEAS, 20. December 2000 (Translation of the letter and parts of the enclosures).
The letter
The Norwegian Water and Energy Directorate (NVE) has today granted licence to Statkraft for the building and management of a windfarm of 144 MW on the island of Smøla, Møre and Romsdal County. At the same time licence is granted and permission is given to expropriate land in order to build a new 132 kV power line from the wind farm to Nordheim transformer station in Tustna municipality.
NVE has denied licences to Nordmøre Energiverk AS (NEAS) and Ørntua Vindkraft AS for the establishing of windfarms of 40 and 4 MW respectively.
NVE accepted the environment impact assessments (EIAs) from Statkraft SF and NEAS on 19 December 2000.
The reasoning for the decisions may be found in the enclosed  Background for the decision of 18 December 2000.
Please find enclosed a copy of the licence document and the enclosure mentioned above.
Complaints against this decision may be filed, look for information in the licence documents.
The enclosure Background for the decision
Background for the decision.
Contents
1. Conclusion
2. The applications
3. Management procedures
3.1 Notification and environmental impact programme
3.2 Applications
4. Comments received (during the hearing)
4.1 Local and regional authorities
4.2 Central authorities
4.3 Nature and environmental protection organisations
4.4 Energy works
4.5 Local and regional organisations and others
5. Additional analyses
6. NVEs evaluations about the consequence analyses
7. Municipal management procedures according to the Planning and Building Act.
8. NVEs avaluation about the applications for licence
8.1 Ørntua Vindkraft AS
8.2 Statkraft SF and NEAS
8.2.1 190 MW of wind farms at Smøla
8.2.2 Wind resources
8.2.3 Economy
8.2.4 Nature and cultural landscape
8.2.5 Noise
8.2.6 Birds
8.2.7 Open air recreation and tourism
8.2.8 Wilderness areas and valuable nature types/protected areas
8.2.9 Other fauna and flora
8.2.10 Infrastructure
8.2.11 Agriculture
8.2.12 Waste and pollution
8.2.13 Shadow effects and reflex flashes
8.2.14 Consequences for society
9. Summary and conclusions
10. Permission to expropriate land for power lines
1.
Conclusion
After a thorough evaluation NVE has chosen to grant Statkraft SF licence to build a 150 MW windpower plant at Smøla island. Nordmøre Energiverk AS (NEAS) and Ørntua Vindkraft AS will not be granted licences for their projects at Smøla island. NVE has chosen to accentuate that Smøla island has favourable wind conditions, topography and space for the establishment of a large windfarm. The windfarm will clearly be dominant in the landscape at Smøla and be visible from larger parts of the island. Due to the flat landscape the windfarm that gets the licence, is perceived as orderly and delimited despite its size.
The windfarm might have negative effects on birdlife in the area. This is especially true for the white tailed eagle that breed in or near the planned windfarm area. NVE can not see, however, that consequences will considerably affect the whole population of white tailed eagles at Smøla.
The environmental consequences as a whole are considered acceptable viewed in relation to the benefits of establishing renewable energy production and the national objective of building windpower that produce 3 TWh by 2010.
Nor the power line to Nordheim transformer station is considered to have considerable negative effects when conditions are set for cabling across the Fuglevåg River and marking of the line in order to avoid collisions with birds on certain stretches. NVE has granted Statkraft SF permission to expropriate according the Expropriation Act in order to acquire land and rights in connection with the power line.
3.1
Notification and environmental impact programme
On 3 December 1997 Statkraft handed in a notification about building up to 150 MW windpower production at Smøla island. The area for the plan included large parts of Smøla (FastSmøla). For the handling of the notification confer NVE-document EK13/98. NVE established an environmental impact assessment programme on 6 July 1998.

3.2
Applications
NEAS filed an application for licence together with the EIA to NVE on 5 January 2000. Statkraft filed an application for licence together with the EIA to NVE on 25 January 2000. The applications and the EIAs were sent on a public hearing on 31 January 2000, with deadline for comments on 14 April 2000. The hearing was published in the following papers:
Nordvestnytt,
Tidens krav,
Norsk Lysningsblad on 10 February and 24 February 2000. The following bodies received the applications and the EIAs: Smøla and Tustna municipalities, Møre and Romsdal County Municipality, the County Governor of Møre and Romsdal, the State Pollution Control Authority, the Directorate for Nature Management, the Directorate for Cultural Heritage, the Coast Directorate, The Directorate for Fisheries, The Civil Aviation Administration, the Norwegian Society for the Conservation of Nature, the Norwegian Society for the Conservation of Nature for Møre and Romsdal county, Nature and Youth, Norwegian Environmental Union, Bellona, Norwegian Ornithological Society centrally and regionally, the Norwegian Mountain Touring Association, the Norwegian Hunters and Fishers? Association, Smøla Hunters and Fishers? Association, Norwegian Farmers? Association for Møre and Romsdal, Norwegian Small Farmers? Association for Møre and Romsdal, Statnett SF (energy work), Istad Kraftnett (energy work), Nordmøre Energy works AS, Statkraft SF.
In addition the Ministry of Petroleum and Energy, the Ministry of the Environment and the Ministry of Agriculture received the applications and the EIAs for information purposes.
NVE arranged a meeting with Smøla and Tustna municipalities, the County Governor and the County Municipality of Møre and Romsdal on 28 February 2000. On the same day a public meeting was held at Vest-Smøla local community building. At this meeting NVE?s formal management procedures were presented, Statkraft and NEAS gave information about their applications and Smøla municipality gave information about the municipal management procedures for establishing a municipal master plan and a local development plan. Approximately 300 people were present.
The application and the notification from Ørntua Vindkraft were sent on a public hearing on 29 March 1999 with a deadline for comments on 2 July 1999. The letter was sent to the same bodies that are listed above. NVE arranged for a public meeting with the municipality, the County Governor and the County Municipality of Møre and Romsdal and other interested stakeholders at Smøla Island on 25 May 1999. About 15 persons participated. On the same day there was a field trip to the potential building area. NVE announced that final conclusions related to the application will take place in parallell with final conclusions about the applications from NEAS and Statkraft.
NVE asked for additional information from Statkraft and NEAS on 30 June 2000. Statkraft has supplied additional information to NVE dated 15 September 2000, 13 November 2000 and 15 December 2000 and NEAS 30 August 2000 and 27 November 2000.
On 12 and 13 September 2000 NVE arranged a final field trip related to the proposed projects by Statkraft and NEAS. Representatives from NVE, Statkraft SF, NEAS, Smøla municipality, Tustna municipality, the landowners, the County Governor of Møre and Romsdal and the Directorate for Nature Management participated in the field trip.
The Smøla project
During spring 1998 the Smøla municipality initiated the establishment of a project that was to coordinate the various planning processes in relation to each other. This included NVE?s management procedures related to notification, applications and EIA according to the Energy Act and regulations related to environmental impact assessments, the establishment of a municipal master plan for windpower production and local development plans and the County Governor?s work with protected area planning for Smøla island. Representatives for the various authorities have participated in the project group. The project has been financed among others by the Ministry of the Environment.
4
Comments to the hearing
NVE has received comments from 49 institutions/organisations/persons related to the hearing of applications and EIAs from NEAS and Statkraft.
4.1
Local and regional authorities
Smøla municipality is positive to the plans about establishing windfarms at Smøla, and gives some specifications about this in a letter of 11 April 2000.
Tustna municipality is positive to the development of windfarms at Smøla island and gives specifications about this in a letter of 7 April 2000.
The County Governor of Møre and Romsdal in a letter of 1 May 2000 expresses among other things the following:
The County Governor advises against NVE granting licence according to the Energy Act for a windfarm of 40 MW for NEAS and for the full development scheme according to step II for Statkraft (150 MW). After a total evaluation the County Governor finds it acceptable to build, as applied for by Statkraft, a windpark of 20 mills giving an effect of 40 MW (step I). The precondition for this advice is that the entry road for the windfarm is built from the south, and that the power line is grounded by cable from the transformer station inside the park and further along the road past the Hinnå River. No proposal for a program of follow-up investigations covering public interests has been forwarded. We assume that a programme covering this will be forwarded to us for comments, and that an eventual licence contains necessary conditions for such investigations.
Møre and Romsdal County Municipality in their letter of 19 April 2000 thinks that from a landscape and environmental perspective the eastern areas should be prioritized for windfarm development and that further development should take place step by step towards the west.
The windfarms will visually dominate large areas where parts have been registered to be important in a national protected area context. A parallell development alongside the existing power line and road would not considerably influence the environmental aspects negatively.
The County Cultural Heritage Director draws the attention to the fact that Statkraft?s step I to a minor extent is in conflict with cultural heritage sites, but that the EIA report is lacking information relative to the underlying reports. Building step II will to a larger extent influence cultural heritage sites that both enjoy automatic protection and cultural heritage sites from more recent time, and the potential of discovering new sites is high. This has not been sufficiently mapped for development stage II (step II).
The Public Roads Administration and Møre and Romsdal Public Roads Administration in a letter of 1 March 2000 claims that the planned development will not be in conflict with any road projects at Smøla.
4.2
Central authorities
The Directorate for Nature Management (DN) has expressed its views about establishments of windfarms at Smøla in letters of 18 May and 22 May 2000. DN recommends building of step I for Statkraft granted that conditons for follow-up investigations are prescribed as part of the licence. DN advises against granting licence for the full development scheme for Statkraft. DN also advises against granting licence for a windfarm of 40 MW to NEAS because they consider the negative consequences for conservation interests to be more serious in this area compared to the Statkraft proposed area further east.
In general DN is positive to windpower production as an alternative energy source finding its realisation in Norway. At the same time it is stressed that in this project there are great uncertainties about the effects for nationally important environmental concerns. Especially now at the outset of wind power production in Norway, large windfarm projects should be established in a step by step manner. When the effects on the natural environment has been satisfactorily investigated and evaluated in view of the preceding steps, an eventual permit may be given for the succeeding steps.
The Directorate for Cultural Heritage (RA) has in a letter of 5 May 2000 made comments to the EIA and the applications. They point out that no total assessment for the two windfarms have been made, and they are of the opinion that the development of one windfarm excludes development of the other and vice versa. The RA advises that licence is given to Statkraft step 1 or alternatively NEAS ? project.
The Norwegian State Pollution control authority has given its views in a letter of 29 June 2000. Temporary building activities are exempt from procedures according to the Pollution Control Act. The consequences of reflex flashes and shadow effects for both projects are negligible.
The Coast Directoratehas in its letter of 29 March 2000 no comments to the applications except that Statkraft must apply for permission according to the Harbour and Coastal Waters Act in order to to put down a cable between Edøy and Solskjeløya islands.
The Civil Aviation Administration in a letter of 18 February claims that the windfarms at Smøla, Hitra and Stadtlandet would mean considerable obstacles to air traffic, and asks that windfarms are marked according to the Civil Aviation Administation?s norms BSL E 2-2. A precondition is that the rotor blades are white and that white warning signals are mounted on top of the motor house. When several windmills are situated in a delimited area, it is acceptable that only the outermost and tallest mills are equipped with warning signals. If not all windmills in the outer edges are marked, the distance between the lights must not exceed 700 metres.
The Directorate for Fisheries and the Defence Command Southern Norway have in their letters no comments to the applications.
4.3
Nature and environmental organisations
The Norwegian Ornithological Society (NOF) in their letter of 5 January 2000 advise against granting licence to the proposed windfarms. Their views are based on location of the windfarm in the largest wilderness area in zone 2 in the lowlands of Møre and Romsdal (is reduced from 30 km2 to 5 km2) and in an area with several red-listed species. Regardless of the EIA quality NOF thinks that the windpower plant should be established in areas with less conflicts. NOF has done some further investigations concerning both EIAs and thinks that the conditions put forward in the EIA programme have not been met , confer points below:
(DN note: The Bern convention knows the views presented by NOF through a separate letter)
The Norwegian Society for the Conservation of Nature, Møre and Romsdal County in their letter of 14 April 2000 strongly advise against the planned windframs at Smøla, and point to the need for countywise plans for windpower.
There are considerable and well documented nature and conservations values at Smøla island. As one may see from the EIA-report, the area in question is important for several red-listed bird species. A development here would be in conflict with Norway?s international responsibility for vulnerable and endangered bird species. The proposed building area for the windfarm is the largest and one of the last wilderness areas, zone 2, in the lowland in Møre and Romsdal County. A development as applied for, would reduce the wilderness area to insignificant remnants. According to responsibilities according to the Convention on Biological Diversity, ratified by Norway in 1993, further encroachments into these types of areas should not be accepted.
The Norwegian Society for the Conservation of Nature, Møre and Romsdal County thinks that primarily we should try to reduce our energy consumption pattern in Norway, but if the use increases all the same, wind energy is one of the best alternatives. A precondition is that one avoids developments in wilderness areas, close to areas with high abundancies of species and rare nature types, close to important cultural landscapes and open coastal areas. The proposed projects will be in conflict with these.
The Norwegian Hunters and Fishers? Association and the Norwegian Mountain Touring  Association in a joint letter of 14 April 2000 advise against giving licence for the proposed windfarms at Smøla in spite of them being generally positive to increased efforts in utilizing renewable energy sources. They support Smøla Hunter and Fishers? Association, Møre og Romsdal Hunters and Fishers Association and the Norwegian National Association for Outdoor Recreation (FRIFO), who all advise against the building of windfarms at Smøla.
4.4
Energy works
Istad Kraftnett AS in a letter of 13 April 2000 has evaluated the need for reinforcement of power lines in the case of increased production from windfarms at Smøla, and has no objections to the proposed projects. An increase at Straumen and Nordheim transformer station of 40MW new power production is acceptable. If establishing 150-190 MW wind power production, there will be a need for a new 132 kV transfer to Nordheim transformer station.
Today?s reserve supply of energy to Smøla is not acceptable in periods with high use.
Nord-Møre Energiverk AS (NEAS) in their letter of 16 March 2000 claim that the managerial disadvantages are negligible of leading a combined 22 and a 132 kV power line from Rangnes to Hestøya. NEAS agrees with Statkraft?s plans for power lines according to their step II and assumes that agreements will be made about the economic relationships of the project.
In a letter of 13 April NEAS would like to permit a 132 kV power line to be combined with their existing lines. A precondition is that NEAS can maintain their obligations as an area commissioner and ownership to the establishments without costs.
Statnett SF in a letter of 12 April 2000 points to existing regulations.
concerning the dimensions of the windfarm. Statnett points to the need for coordination between the two proposed parks, and thinks that there is no room for both projects without considerable reinforcements of the regional and central power line system.
4.5
Local and regional organisations and others
Smøla SV (a political party) in its letter of 11 April 2000 claims that a windfarm at Smøla would be a visual
pollution in the flat landscap.
Smøla Venstre, Arbeiderparti, Senterparti og Kristelig Folkeparti (political parties) in their letter of 14 April 2000, look forward to the establishment of windfarms at Smøla in order to create more commercial development and optimism in a municipality, that have great challenges concerning people moving away from the municipality and the loss of jobs.
Smøla Høyre (a political party) in its letter of 9 April 2000 is positive to the development of wind power production at Smøla, but has comments ------- (concerning localization in relation to infrastructures)
Motvindaksjonen (the Contrary wind action) in letters of 11 and 12 April 2000 advises against wind power production at Smøla because:
- wind power production is expensive and the societal and business aspects of the projects are not clear
- the effect value for wind power production is almost zero
- there are no compensation schemes for the affected landowners yet
- the municipal administration is regarded as biased supporters for the applicants
- the windfarms will constitute large encroachments at Smøla and are regarded as visual pollution and will have negative consequences for fauna,
- the development will reduce wilderness areas at Smøla contrary to national objectives
- it is questionable whether the building of a wind power plant is a reversible encroachment
- the development will be in conflict with important birdlife interests, where especially the white-tailed eagles, great loons and swans are vulnerable species
- ..
- the conservation plans for Smøla have not been decided yet
- ..
- the localisation of windfarms at Smøla is contrary to both NVE?s and Statkraft?s established localisation criterias
-
50 residents of Smøla (according to signatures) in a letter of 9 March 2000 are positive to the development of wind power plants at Smøla. They think that this will be advantageous for the municipality and lead to new optimism in the Smøla community.
5.
Additional analyses
In a letter of 30 June 2000 NVE asked Statkraft and NEAS for additional information. Such information was to cover effects on birdlife, costs of cabling stretches/eventual joint power lines with existing power lines, consequences for hunting and effects on radio and TV signals. In addition Statkraft had to describe the effects on the landscape picture of the establishment of the wind mills in right lines, the possibility of moving the transformer station, entry road and the consequences of moving the northernmost windmills. NEAS was asked to give further information about the effects of noise and the effects on wilderness areas.
NVE has received 12 comments to the additional information obtained.
(DN note: The following institutions/organisations made comments: 1)The Directorate for Nature Management (See enclosure 5 to this letter), 2) Motvind-aksjonen (the contrary wind action), 3) Project White-tailed eagle under the auspices of the Norwegian Ornithological Society, 4) The Norwegian Ornithological Society (NOF), 5) BirdLife International, 6) The Norwegian Society for the Conservation of Nature, Møre og Romsdal, 7) The Norwegian Society for the Conservation for Nature, 8) The Norwegian Hunters? and Fishers? Association, Møre og Romsdal region, 9) The mayors and the council for head municipal advisers at Nordmøre municipalities, 10) Istad Kraftnett AS (energy work), 11) Nordmøre Energiforsyning AS (NEAS), and 12) Telenor.
The Norwegian Ornithological Society (NOF) stresses the need for a comprehensive plan for windpower production in their letter of 22 November 2000 to NVE and DN. The establishment of windfarms in Norway must be evaluated according to agreed criterias. They realize that the processing of the present applications for licences can not be postponed awaiting a comprehensive plan, but asks that an extensive evaluation of the present applications is made. NOF has made a comparison based on the effects on species like the white-tailed eagle, red-throated diver, whooper swan and the reduction of wilderness areas.
According to the evaluation of NOF the proposed windfarms at Smøla must be ranged as the environmentally most negative one and most conflictual compared with all the other plants that now have been registered and are available at NVE, and this makes a localization of the proposed areas at Smøla incompatible with the characterization of windpower production as an environmentally sound form of energy.
6. NVE?s evaluation of the EIAs
(DN note: The NVE evaluation of the EIAs includes the following topics: a comprehensive plan for windpower production, visualization, open air recreation and tourism, noise including infra- sound, birds, cabling/moving the transformer station, cultural heritage, power line connections, follow-up investigations, and synergetic effects of the projects).
Conclusion:
On the basis of the EIAs of 25 January 2000 from Statkraft and 5 January 2000 from NEAS, additional information of 15 September, 13 November and 5 December 2000 from Statkraft and 30 August and 27 November from NEAS and received comments, NVE finds that the obligation has been fulfilled to carry out an assessment pursuant to the EIA and the regulations of the Planning and Building Act chapter VII-a including its regulations.
7. Local development plan
(DN note: The letter says that a municipal master plan and a development plan for windpower production at Smøla will be finally decided in January 2001)
8. NVE?s evaluation of the applications for licence
(DN note: NVE?s evaluation of the applications for licence includes elements like: nature conservation and cultural heritage, noise, birds, open air recreation and tourism, wilderness areas and protected areas and candidates for protection, other flora and fauna, infrastructure, agriculture, waste and pollution, shadow effects and reflex flashes and societal consequences.)
8.2.6 Birds
Registrations that the White-tailed eagle Project has carried out in the year 2000, shows that 5 pairs of white tailed eagle have their breeding grounds within 1 kilometres  (km) from infrastructure in the proposed NEAS windfarm, and a further 5 pairs within 2 km. For the proposed Statkraft step I the corresponding numbers are 6 and 9 pairs, and for step II, 12 and 13 pairs. The total breeding population of white-tailed eagle at Smøla is estimated at 65-70 pairs. Out of 35 registered nests at northwestern Smøla, 25 are in the affected wilderness area.
Collisions between birds and windmills are not regarded to be a considerable problem. An exception from this could be that the birds are attracted to signal lights on the windmills during dark and thereby collide. Whether this is true or not, we do not know. The most important consequences for birdlife at Smøla is regarded to be displacement from the breeding and foraging grounds and increased danger of collision with power lines.
According to the knowledge available to NVE the population of white-tailed eagle is growing along the larger part of the Norwegian coast and the species is no longer thought to be in danger. At Smøla there will also after the development of windfarms be viable populations of white-tailed eagle. There is little reason to believe that the status of the white-tailed eagle in Norway will be changed even though a number of pairs are displaced from their breeding grounds at Smøla.
8 Summary and conclusion
In view of the given environmental impact assessment, additional information and given comments NVE regards the obligation to undertake environmental impact assessment pursuant to the Planning and Building Act chapter VII-a as fulfilled.
From NVE report 19/98 it is apparent that NVE accentuates the following elements in processing applications for licences:
. ample wind resources and moderate production costs
· a certain minimum size of the project
· favourable location in relation to existing infrastructure
· acceptable effects on infrastructure
· low level of conflict with important cultural landscapes, nature areas, vulnerable landscapes and species
A decision for licence is based on a total evaluation of the following relationships.
Wind and production
Wind velocities over the year of 7,5-8 m/sec for a larger area is considered by NVE to be good wind resources. The costs of development are regarded as acceptable. The projects are not profitable from a business point of view, but depend on state subsidies. For projects that have received state subsidies up to now, the subsidies mean approximately 0.1 NOK/kWh.
It is a national objective that 3 TWh wind power is produced in Norway by the year 2010. With approximately 3000 hours user time, it means an installed effect altogether of 1000 MW of wind power in Norway. NVE thinks that it is better to concentrate the production in larger entities in some areas than to establish a number of smaller windfarms along the coast of Norway. NVE thinks that there are few places in southern Norway that geographically is as well suited for the location of a large windfarm.
Infrastructure
A road for the entry to the proposed windfarms and road internally inside the windfarms need to be built. The building of roads in NEAS? area would lead to large encroachments into the natural environment and have more negative landscape effects than the building of roads on the flat moor areas where Statkraft wishes to build. The regional net in Nordheim transformer station has the capacity of accepting relatively large amounts of new energy. Due to the fact that the power lines are to cross through relatively untouched wilderness areas, NEAS?s proposed power line is considered more unfavourable than that of Statkraft. The crossing of a power line across Fuglevågen is regarded as negative for birdlife in the area as this is a natural migration route for among others swans and loons. The risk of collisions may be reduced by using cables across the river.
Effects on infrastructure
All the proposed projects are situated in relative good proximity to the housing areas of Smøla. It is considered that there are no considerable disadvantages in relation to visual dominance and noise for the housing areas. By development of 150 MW according to Statkraft?s application, 7 recreational houses and one small farm will receive noise levels over 40 dBA. This is considered disadvantageous.
Level of conflict in relation to conservation and cultural heritage
In relation to nature conservation and cultural landscape values there are differences in the proposed alternatives. Both in relation to effects on landscapes due to wind mills, infrastructure and conflicts with cultural heritage interests, the environmental impact assessments and received comments, the level of conflict is reduced towards the east. The western areas are supposed to be of higher conservation value both with respect to zoology, especially birds and botany. In addition, NEAS? proposed park is situated closer to the characteristic coastal housing at Smøla.
No matter what location is chosen for a windpark, breeding white-tailed eagles will be affected. The conservation interests are considered greatest close to the western coast. NVE thinks that an establishment of 150 MW is acceptable with respect to white-tailed eagles. 12-13 breeding pairs of white-tailed eagles may be affected, but NVE supposes that this will not have considerable negative effect on the population of Smøla as a whole.
Total evaluation
After an evaluation of the consequences for landscape, cultural heritage, open-air recreation, birds and so on, NVE thinks that the consequences for nature and cultural heritage will be acceptable for establishing wind power production in the Statkraft?s proposed area. NVE will however set conditions for alternative measures in order to reduce the consequences where this is considered necessary. NVE would like to grant licence for the establishment as applied for, with the exception of the northernmost windmill in the three westernmost rows for step II. An eventual altered localisation of windmills will call for a new application for licence according to the Energy Act.
From the viewpoint of aesthetics, road building, effects on birds and consequences of the power line, an establishment on the proposed NEAS area is considered to involve more conflicts than the Statkraft development. After a negotiation meeting between Smøla municipality and the County Governor the NEAS planned area is removed from the municipal master plan for windfarms. Taking into consideration the total effects especially related to aesthetics and birds, NVE concludes that NEAS should not be granted licence for the proposed development.
NVE does not wish to grant licence to Ørntua Vindkraft AS for their proposed project. It is desirable that the windfarms are co-located, both from a landscape, open-air recreation and bird perspective.
The following conditions for alternative measures will be requested in a licence to Statkraft
· The power line shall be cabled from the end of the windfarm and across the Fuglevåg River approximately 1500 metres. In addition the power line shall be marked in order to reduce the danger of bird collisions from Smøla transformer station to the point where the cable starts, from the cable and to Hinnå River, and across the Fjøtjønna Lake. Statkraft must make available a plan for the cabling activities in due time before the start of the building activities.
· The northernmost windmill in the three westernmost windmill row for step II shall be removed. Statkraft may apply for permission to place these mills in another part of the windfarm if other suitable locations can be found. Statkraft shall bear the costs of eventual necessary alterations to the marked  trail from Kvistvågen to Dyrnes
· Sand and gravel products from the building processes shall be re-located to the roadside  (shoulders) after the building period is over.
· Power lines that are no longer in use after the new 132 kV power line is installed shall be removed. This must be done in agreement with NEAS who owns the power lines.
· In order to get a better basis for eventual follow-up investigations related to effects on birdlife, Statkraft should make registrations of birds from the time that the work starts. A plan for the carrying out of such registrations shall be approved by NVE. Furthermore Statkraft shall make a plan for follow-up investigations. This plan shall be addressed to and approved by NVE before the windfarm is in operation.
· When the windfarm is established, pictures should be taken from the same locations as the visualisations presented in the environmental impact assessment. A comparison between the visualisations and the reality shall be made both at finishing step I and step II.

Enclosure 7

DNs comments to the complaints (Excerpts from DN?s letter dated 26 February 2001).
The Directorate for Nature Management (DN) has received copies of eight complaints concerning NVE?s decision to build windfarms at Smøla. Once more, we would like to emphasise that in general DN is positive to the development and building of windfarms, but considers it necessary to find reasonable solutions in order to avoid devastating conflicts between the building of windfarms, environmental values and other interests of society.
DN would like to accentuate some arguments from the complaints that are in accordance with our earlier comments to the public hearing. Main arguments from our earlier comments concerning the building of windfarms at Smøla:
· From an overall point of view DN recommends that licence could be granted to Statkraft step I for 40 MW. Based on the existing knowledge it is however not considered environmentally sound to carry out any larger development.
· According to the DN recommendation a precondition for licence is that follow-up investigations are carried out.
· We would like to emphasise that based on the knowledge gained during building step I it must be objectively considered whether a further development of the windfarm is to be accepted (step II).
· It is a precondition that the power line is grounded by cable from the transformer station inside the park and past the Hinnå River.
In addition we would like to accentuate that we in various connections have emphasised the general need for a comprehensive management plan for wind power production in Norway, as a tool for local, regional and national decision-makers.
It has also been emphasised repeatedly to NVE that the investigations that exist from Denmark and England on environmental issues relative to windfarms are of limited transfer value to this project. Investigations that are more comparable to the Norwegian situation conclude that there is a considerable death rate of raptors due to collisions with windmill constructions. Based on the precautionary principle DN has proposed that the first projects to be built should be defined as reference projects. Extensive before-, during- and post-investigations would lead to a better basis for decision making for windfarms in the future.
NVE argues against a comprehensive plan for windmill farming because the best safeguard in order to follow-up the political objectives and at the same time choose the right localities, is to secure a gradual learning process from given licences and available data. Against this background we think it is regrettable that NVE disregards the professional scientific and nature management views that have been expressed during the EIA, and gives licence to Statkraft for the building of both step I and II at the same time.
The complaints from the nature conservation organisations and other NGOs mainly concentrate on the same elements that DN has pointed out.

Enclosure 8

NVE?s decision about windpower production at Smøla Island of 20 December 2000 evaluation of the complaints (Excerpts from the letter of 20 March 2001 to the Ministry of Petroleum and Energy)
Conclusion
NVE does not find that any significant new information has been brought forward that implies that NVE should change its decision made on 20 December 2000. NVE will therefore maintain its granting of a licence to Statkraft in order to establish a 144 MW windpower production plant at Smøla Island. NVE also announces that it maintains its decisions made on the same date to deny the applications from NEAS and Ørntua Vindkraft AS for licences.

Enclosure 9

Letter from the Ministry of the Environment to the Ministry of Petroleum and Energy, dated 10 July 2001; Complaint concerning NVE?s decision to grant licence to Statkraft SF for the building of a wind power production plant at Smøla (Excerpts from the letter).
We refer to your letter of 14 June 2001 where the Ministry of Petroleum and Energy asks the Ministry of the Environment for an evaluation concerning NVE?s decision to grant licence for the establishment of a wind power production plant at Smøla of 20 December 2000. We also refer to an on-the-spot appraisal at Smøla 15 May 2001.
The Ministry of the Environment recommends that the Ministry of Petroleum and Energy should maintain NVE?s decision to grant licence for both step I and II. The Ministry of the Environment however thinks that the development of step II should take place only after the actual effects of step I have been documented.
The Ministry of the Environment thinks it is very important that mitigation measures are carried out in order to limit the negative effects as much as possible. The requirement for such measures should be defined presicely in the conditons for licence. The conditons for licence should also require thorough before- and post- investigations for step I in order to obtain the best posssible basis for defining contents and extent of the mitigation measures. In addition the Ministry considers it a precondition that there is a dialogue between the petroleum and energy authorities and environmental authorities when defining mitigation measures.
The Ministry of the Environment has no remarks concerning the decisions not to grant licences to Nordmøre Energiverk AS and Ørntua Vindkraft AS.
2. Effects on the environment from Statkraft?s planned windpower production plant at Smøla.
28 red listed species and 12 responsibility species of birds have been registered at Smøla. Of these it is probably most important to protect the loon (Red throated Diver), the whooper swan, the dunlin (ssp schinzi), the Smøla Willow Grouse and the white-tailed eagle in order to avoid a reduction in the populations.
A central topic in this case is the effects on the white-tailed eagle. Smøla has the highest density of breeding pairs of white-tailed eagles in the whole world, and 65-70 pairs of white-tailed eagle breed on the island. The main part of the population breed south of the planned windfarm. In the windfarm area 10-12 pairs are breeding, and the density here is the highest in the world. In Norway the status of the white-tailed eagle in our red-list is care-demanding because of a positive population trend over the last years, while it earlier had status as vulnerable. On the global red-list the species has a status as vulnerable, and Norway has a global responsibility for safeguarding and taking care of this species. 45% of the European population lives in Norway. Due to the consequences for the white-tailed eagle Norway has a complaint against her in the Bern convention for possible breach on the convention.
The windmills might be the cause of collisions between the white-tailed eagle and rotor blades, and loss of breeding sites because the eagle needs a certain distance from human activities when deciding on its breeding site. The Ministry of the Environment consequently is of the opinion that the breeding sites will be lost within the windfarm itself and also in a certain distance beyond the windfarm. The development might also have negative consequences for the other bird species at Smøla, inter alia in the form of displacement, reduced population and danger of collision.
Smøla has the three largest wilderness areas in the lowland of Møre and Romsdal County, and the planned windfarm is situated within one of them. This area is, contrary to the other two, not a priority in the county development plan for wilderness areas in the county. All areas belong to zone 2, i.e. 1-3 kilometres from heavier encroachments.
The visual/aesthetic consequences have been mentioned by several institutions/organisations. The windmills that are planned for are 110 metres high and will be quite dominant visually. The windfarm will among other things have visual effects for the southern parts of Smøla, that is an important cultural landscape with low degree of technical encroachments. Visual effects will however arise for all wind power production plants.
The rotor blades of the windmills produce noise. The estimates for noise in the EIA show that in a worst scenario (building step I +II), 2 cabins and a small farm north of the plant,  and 4 cabins and one open-air recreational area south of the plant will receive noise levels above limits of the Norwegian State Pollution Control Authority. In addition a number of houses (20-50) north and west of the plant will be able to hear noise from the plant.
The windfarm area is used for recreational purposes. The most frequently used open-air recreational area at Smøla, the area along the Fuglevåg River, is however situated outside the area that has been regulated for wind power production purposes.
The Ministry of the Environment would like to accentuate that not only the windmills, but also development activities, internal roads of the windfarm, and power lines might have negative effects for important environmental values.
3. Strategy for wind power production plants in Norway
Some of the complaints advertise for a comprehensive plan for wind power production in Norway. In this question The Ministry of the Environment would like to note that a countrywide comprehensive plan for wind power production would call for a large number of potential localities being considered. In order for such a plan to form the basis of actual projects, one first needs to make thorough wind velocity measurements in the field. After that there is a need to clarify capacity and costs for power transfer from the parks. In addition there would have to be evaluations of infrastructure like roads and harbours, before the disadvantages for the environment in each location could be evaluated. Such processes would imply lots of time and costs. If a comprehensive plan at the same time should have any impact on the measures that are already planned, or for the measures where given licence have already been complained about, or where there is a complaint according to the Planning and Building Act, this would imply that the Government objective of 3 TWh wind power production by 2010 would not find its realisation. Due to the time and resource consumption of such a plan and from the alternatives schemes given below, it is the evaluation of the Ministry of the Environment that it is not feasible to work out a comprehensive plan for wind power production.
The Ministry of the Environment would however like to stress that we wish wind power production plants to be established in areas where the levels of conflicts in relation to other environmental considerations are as low as possible. As a basis for evaluating the level of conflict for the various windfarms, the Ministry has commissioned the Directorate for Nature Management (DN) and the Directorate for Cultural Heritage (RA) to make a report in order to evaluate environmental values and levels of conflict for the 13 wind power production plants that were notified or were granted licence by the end of April this year. These evaluations will be further developed for other planned wind power production plants.
Furthermore a project will be carried out where a systematic evaluation of the cases that to date either have been notified according to the regulations for EIAs according to the Planning and Building Act or have been granted cocession by the Norwegian Water and Energy Directorate (NVE). The lead agency for the project is NVE, who will cooperate with DN and RA. These will contribute with evaluations of environmental values and conflict levels of planned windfarms. This work is meant to give systematised knowledge about area and environmental conflicts related to wind power production plants. The work would form the basis of developing an advisory policy document for the establishment of windfarms. Such a document would contain a set of principles or a guideline for the establishment of wind power production plants.
The Ministry of the Environment thinks that county development plans for wind power production would contribute to principal evaluations of the feasibility of the area for windfarms. County development plans should also form the basis for relevant plan decisions and at the same time be of help for the regional authorities when considering actual applications for licences concerning wind power production. The Ministry of the Environment has therefore supported an application from the County Municipality of Sør-Trøndelag for the development of a county development plan for wind power production.
4. The Ministry of the Environment evaluation related to the complaints concerning Statkraft?s plant.
It is a Government decision that 3 TWh of wind power production should be built by 2010, cf Report to the Storting No. 29 (1998-99) About the Energy Policy. It is very important for the Ministry of the Environment to contribute to the realisation of this objective, and the Ministry thinks it is important that construction works starts next year. At Smøla a municipal master plan has been developed, and there is concensus within the municipal board for the development plans. The conditons are therefore good for starting constructions at Smøla without delay.
At the same time the Ministry of the Environment views it as important that wind power production plants are established in areas where the environmental effects are as small as possible, and that it is signalled that wind power production plants can not be established independently of the environmental effects. In this connection we refer to Report to the Storting No. 42. (2000-2001) Biological Diversity where the Ministry of Petroleum and Energy stresses that the incentive to reduce negative effects of windpower production is first and foremost to localise windfarms to areas with acceptable effects on biological diversity.
The planned windfarm, and especially step II, might have negative effects for central environmental values, and step II is one of the plants with the highest level of conflict among the ones that today is considered possible to finish before 2010. The Ministry of the Environment would therefore like to recommend a step by step development at Smøla, where step II is developed after the effects of step I is investigated and evaluated. The believed effects of Statkraft?s plant is in our opinion supportive of a step-by-step development. In this connection we refer to a step-by-step development for windfarms that has be used e.g. in Denmark.
The Ministry of the Environment is especially concerned about the effects on the biological diversity, and in particular the bird population at Smøla. The consequences for the white-tailed eagle are central to this case, but the Ministry of the Environment is of the opinion that we need more knowledge about the actual effects on eagles and other biological diversity, before we can make accurate statements about their importance for a further development at Smøla. In Denmark and other EU countries all socalled EU-bird areas are, according to our knowledge, exempt as localities for wind power production. This would include all breeding localities for white-tailed eagles. The same would have been the actual policy in Norway if the Habitats and Birds Directive were a part of the EEA-agreement.
A step-by-stepdevelopment at Smøla would be a good opportunity to gain experiences about the consequences of wind power production plants in Norwegian nature. Such knowledge is to date not available. By making Smøla a national reference area for wind power production, including before and post investigations for step I, one would be able to gain important knowledge that would be useful at later evaluations of further development at Smøla, and in relation to other projects that have been notified. It is especially important to clarify the effects for birds, but also peoples? experiences with the windmills and the consequences for other environmental values should be studied. Requirements for before- and post-investigations should therefore be part of the conditions for licence. We think that both the authorities and Statkraft should contribute financially to the carrying out of such investigations.
The Ministry of the Environment also views it as important that mitigation measures are carried out in order to limit the negative effects of the project as much as possible. A requirement for such measures should therefore be defined precisely in the conditions for licence. Before- and post- investigations for step I are important in order to obtain a best possible basis for defining contents and extent of the mitigation measures. The Ministry considers it as a precondition that the environmental authorities are contacted when determining the content and extent of the mitigation measures.
The Ministry of the Environment would like to stress that the applications for wind power production plants now is so extensive that the objective of 3TWh by 2010 would be reached even though Smøla II were not developed.

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