The proposed Kouga Wind Farm - St Francis Bay Residents Association

In the context of South Africa’s energy requirements, and the need to reduce dependence on fossil fuels, any move towards an economically viable, affordable, clean, renewable, and sustainable power generation technology is to be welcomed.

However, the urge to provide such a technology does not remove the need for rational assessment of each proposal in terms of its geographical situation, its environmental impact, and its economic viability. The current EIA with regard to the proposal to place up to 150 2Mw turbines in the St Francis/Oyster Bay area needs to investigate all of these factors.

The proposed Kouga Wind Farm

The proposal to erect 150 turbines in this area represents a massive policy shift with regard to land usage for the Kouga area. We are not considering here a couple of wind turbines, but a major change, to industrial usage.

Hitherto, the principal land usage of the Humansdorp/St Francis area has been to accommodate agriculture, holiday resorts, tourism and retirement, all of these extremely successfully. In the event that both the Thyspunt nuclear site and the Kouga Wind Farm go ahead, the major role of this area will become power generation, with an inevitable move towards industrialisation of the whole area, as has occurred at Mossel Bay. Even without Thyspunt, 150 turbines would change for ever the character of the landscape in this area.

Allowing optimistically for 33% efficiency from the wind Farm, the average output of 150 2 Mw turbines will be 100Mw. At 25% efficiency, which is high by world standards, only 75 Mw would be generated on average. This compares with a consistent output from the proposed nuclear plant of approximately 3000Mw. In other words, to achieve the equivalent output at 100 Mw would require 30 such wind farms, or 4500 2Mw wind turbines. At 25% efficiency, it would require 40 wind farms comprising 6000 turbines.

Even then, back-up would be required to compensate for fluctuations in wind.

To achieve even the modest output of 100Mw, the environmental price will be a massive visual intrusion. The question facing decision-makers is whether such a change is warranted for such a small return, in an area which has established itself so successfully in other directions.

The premature EIA process

The Background Information Document (BID) is extremely vague on almost every aspect of this project. It states that there will be between 50 & 150 turbines, of 2-3Mw capacity, spread over three large areas, with no indication as to how these will be distributed. Nor is the specific wind generation technology specified.

Attention is drawn to Section 31 of Regulation No R385, promulgated in terms of Chap 5 of the National Environment Management Act (No 107 of 1998) (Consideration of Scoping Reports), which states that the competent authority must . . . consider the report and in writing reject the scoping report (Sub Section 1 c) . . . if it does not contain material information required in terms of these regulations.

In our view, the same objections apply to this EIA as to the EIA for Thyspunt, namely that the BID is deficient in material information required for the making of a decision in terms of the NEMA regulations. It is not possible for the public to respond, unless the specifics of the project are spelt out.

As an example, it is clear that the Krom Bay properties would be the first choice of the developers, because of their easy road access, and short transmission line requirements to the existing Eskom 66kv line to St Francis. However, these properties are by far the most visible from virtually 360 degrees, and could have a serious auditory impact on the Paradise Beach community. The least impact, both visual and auditory, would be on the Gibson Bay properties, but they are the least accessible and most expensive, both for roads and transmission lines. It stands to reason that the developers will seek to place the maximum possible number of turbines on the Krom Bay properties. This could exceed fifty, if the worst-case scenario takes place. Without such information, it is impossible to respond.

In our view, the specific technology, numbers and siting of turbines are material information, which should be contained in the BID. We therefore submit that this EIA should be discontinued until such time as the developers are able to supply all relevant details of the project.

Experience elsewhere

It is clear from available documentation that experience of wind generation elsewhere in the world has not been entirely positive. The leading country in the world in terms of wind generation is Denmark, which had 6000 turbines in September, 2006. Yet the Danish government cancelled plans for three off-shore wind farms planned for 2008, and has scheduled the withdrawal of subsidies from existing sites. Development of onshore wind farms in Denmark has effectively stopped, and the Chairman of the Danish Parliamentary Energy Commission is quoted as describing Denmark’s wind generation policy as a “very, very expensive catastrophe”. There may be a political agenda here, with “greens” and “reactionaries” in opposite camps.

Denmark is not alone in reviewing its wind policy. Spain began withdrawing subsidies in 2002; Germany reduced the tax breaks to wind power, and domestic construction drastically slowed in2004; Switzerland is cutting subsidies as too expensive and lack of significant benefit. The Netherlands de-commissioned 90 turbines in 2004; many Japanese utilities limit the amount of wind –generated power they buy because of the instability they cause; for the same reason Ireland in 2003 halted all new wind-power connections to the national grid; in 2005 Spanish utilities began refusing new wind-power connections, and in 2006 the Spanish government ended its subsidies and price supports. In 2004 Australia reduced the level of renewable energy utilities are required to buy, dramatically slowing wind-project applications. In 2004 it was reported that “the unstable flow of wind power in their networks” had forced German utilities to buy more expensive energy, requiring them to raise the price to the consumer.

A 1998 Norwegian commission, admittedly a decade out of date, concluded that wind power had “serious environmental effects, insufficient production and high production costs”. It is up to the proponents of the project to show that this has changed over the past decade.

It has been alleged that Danish electricity costs for the consumer are the highest in Europe. Because of the unreliability of supply, and the difficulty in correlating alternative supply sources when the wind is too light or too strong, it is reported that in 2003, Denmark exported 84% of its wind-generated electricity, and in 2004, 70.3%, at a loss. No conventional power plant has been shut down, and there has been an increase in CO2 emissions.

If technologically advanced countries are having problems with wind generation, it is predictable that we would have similar problems.

There must be a reason for this strong reaction against wind power.

It is clear that a very critical examination is required of the economic benefits of wind power, together with the impact which it will have on the grid system.

Output efficiency elsewhere

Throughout the developed world, wind turbines have produced, on average, less than 20% of their theoretical, or rated, capacity. Here are some figures:

Germany 1998 -2003 14.7%

It is a bold man, therefore, who claims that the Kouga Wind Farms will operate at 33% efficiency, as was stated at a public meeting. This would need to be established, as it affects the entire socio-economic viability of the scheme.

Environmental impact

The most serious environmental impacts are the visual and auditory, plus impact on birds and bats.

Any turbine which is 80 – 100 metres high, with blades of 40 – 50 metres in length, has to have a visual impact. A cluster of dozens of turbines must inevitably be in multiples of this impact. Placed in conspicuous positions, such as the Krom Bay properties, they would be highly visible, changing the landscape for ever.

The visual impact relates not only to the sheer size of the towers, but to such matters as flicker, both in terms of reflection of sunlight and shadow on either side of the turbines. These have proved to be a problem to adjacent communities, and reflection could be observed from many miles away in open areas.

Not only do the huge magnetised generators unavoidably cause a low-frequency hum, but every time a blade passes the tower the compression of air produces a deep resonating thump. The resulting sound of several towers together has been variously described as being as “loud as a motorcycle”; “like aircraft passing continually overhead”; “like a train that never arrives”; and “like unceasing thunder from an approaching storm”.

The penetrating low-frequency thudding vibration, like the throbbing bass of a neighbouring disco, travels much further than the usually measured “audible noise”. Residents up to 3 miles downwind in otherwise quiet rural areas suffer significant noise pollution.

Following a five-year investigation, the E.U. found noise complaints to be valid, and that noise levels could not be predicted before developing a site.

Communities in Germany, Wales and Ireland claim that even one kilometre away the noise is significant. Individuals from Australia to the U.K. say they have to close their windows and turn on the air conditioner when the turbines are active. Numerous reports of this nature can be cited.

The proponents of the scheme argue that only a few thousand birds are killed annually by wind turbines (my recollection is 28000). A 2002 study in Spain estimated that 11,200 birds of prey (some endangered), 350,000 bats and 3 million smaller bird are killed each year by wind turbines and their power lines. Another survey found that on average a single turbine kills 20 – 40 birds each year. On this estimate, wind farms of 150 turbines would kill up to 6000 birds annually in our area. Especially vulnerable are large birds of prey. Blue Cranes frequent the proposed Krom Bay area Guidelines from the U.S. Fish & Wildlife Service state that wind towers should not be near wetlands or other known bird or bat concentration areas.

Economic impact of the proposed project

The major economic impact for the area would be in terms of compensation to land owners for the use of their land. They are likely to be strong supporters of the proposal. It is also argued that an area with wind farms will be spared electrical outages, since the utility requires to keep the lines open to accept power generated by the turbines. This may be correct.

There are few other economic benefits, and some likely negatives.

Job creation would be absolutely minimal. Of the 200 workers involved in construction of the 89-turbine “Top of Iowa” facility, only 20 were local, and seven permanent jobs were created. Much the same is likely to happen here.

Would the proposed wind farms have a positive or negative impact on tourism? The proponents argue that they would strengthen tourism, since a few people visit wind farms out of curiosity. But visitor centres at wind farms in Britain are closing down for lack of business. On the other hand even surveys by wind promoters show that a quarter to a third of visitors would no longer come if wind farms were installed. That is a huge loss to areas which depend on tourism, and Tourism has been identified as the top economic priority for the Kouga Region.

One of the requirements of the EIA process is that consideration be given to alternative sites. It is very clear that, whatever the benefits of the proposed wind farm may be, they would have a significantly negative impact on the Paradise Beach/St Francis area.

The obvious place for power generation in the Eastern Cape is the area around Coega. This is scheduled to become an Industrial Development Zone. It is close to the existing substations of Grassmere & Deduka; the whole area is in the process of being environmentally degraded; and there are large tracts of land there which must have similar wind patterns to those of this area. It would make far more sense to build wind farms in that area than in the Humansdorp/St Francis area.

Matters for incorporation in the Scoping Report

The view that the EIA process is premature is repeated. (See section 3 above).

Should the EIA proceed, and in the light of what has been said above, we request that the following matters be included for investigation in the Scoping Report:

Whether wind farms comprising up to 150 turbines are consistent with the land use policies for the Kouga Municipal area.
Whether the relatively modest output from such wind farms justify the undeniable environmental impact of the proposal.
Detailed examination of experience elsewhere in the world of the social, environmental and economic impact of wind generation, with specific attention paid to reasons for reducing dependence on wind power in the developed world .
Specific and detailed attention to the probable visual and auditory impact of the proposal.
Evaluation of the threat to bird life and bats in the three identified areas.
The cost effectiveness of wind generation as against other types of power generation.
Investigation of alternative sites for wind farms, with particular reference to the Coega area.