Polish Wind Energy Association position paper concerning the open letter to the Prime Minister signed by the Safe Energy Coalition

Polish Wind Energy Association (PWEA) acquainted itself with the open letter of the Safe Energy Coalition addressed to the Prime Minister, published, among others, in the Self-government Portal on 12 November 2012.

We find it containing many false information that may mislead persons making decisions concerning the state energy policy as well as the public. We feel obliged to present the following disclaimer. Furthermore, we kindly request the launch of actions to develop and implement a programme of a broad educational and information campaign that will enable the presentation of actual benefits and limitations related to the use of renewable energy sources (including wind energy). The lack of reliable knowledge concerning renewable energy sources (RES) is increasingly apparent in the public debate and becomes the reason for illegitimate public anxiety and extension of investment procedures. The situation of particular projects may translate into difficulties in achievement of assumptions stemming from the National Renewable Energy Action Plan.

Referring to the letter in question we would like to inform that wind energy investments, similarly to any other projects, are subject to relevant building[1], planning[2], environmental[3],[4],[5],[6],[7], energy[8] and other regulations that enable them to operate pursuant to the terms and conditions applicable to investments from other industries. Wind energy investments are usually implemented using equity, what requires substantial investment and administrative works; however, the investment costs per unit of installed capacity are one of the lowest in the entire RES sector (approximately 1.6 million EUR/MW). Poland exhibits large but still mostly unexploited wind energy development potential – comparable to that of Germany (currently installed capacity in Poland amounts to 2 341 MW[9], a small part of more than 6 500 MW[10] planned in the NREAP by 2020, and an insignificant part of 29 085 MW installed in Germany at the end of 2011). Therefore, the growth we are facing is much below the actual capacity, which pursuant to the Renewable Energy Institute amounts to 13 000 MW in 2020[11]. Wind energy development brings substantial revenues for communes (from real property tax) and entire regions (from CIT) and as much as possible uses local labour.

Contrary to the presented opinions there is no clear relation between wind farm location and real property value or attractiveness of an area for tourists. Many communes develop their tourist image on the basis of green energy (e.g. Margonin commune) or confirm that the construction of RES facilities on their area does not affect the tourists’ interest (e.g. Wolin commune). Depending on the location procedure a wind farm construction enables broad and common public participation in the consultation of planned projects (three times in the full planning procedure – at the commune’s land use plan adoption, the commune’s local spatial development plan adoption and exposure of the investment’s environmental impact assessment report stage). These rights stem from the so-called EIA Act[12] and enable each interested person to participate in the consultations; persons, whom the investment directly pertain to additionally participate in the procedure upon the rights of a party. It has to be stressed that it is a common investors’ practice to implement additional educational activities on the area of the commune and organise consultation meetings with the local community, hence to take initiative substantially exceeding the statutory obligations.

The EIA Act referred to in above also obligates an investor to submit an EIA report for the investment. The reports are developed for all projects upon the investor’s request by professional experts and approved as well as verified by relevant administrative bodies (including District Sanitary Inspectorates and Regional Environmental Protection Directorates). Therefore, environmental impact is thoroughly assessed and many times verified by subjects independent from the investor. The report thoroughly analyses all potential environmental impacts and effects on humans. Contrary to the opinions presented in the open letter, published reliable scientific papers demonstrate that wind energy does not exhibit adverse impact on human health (cf. for instance the Polish Academy of Sciences’ report on Kujawsko-Pomorskie province[13]). It is the most health- and environment-friendly energy technology (pursuant to the World Health Organisation – WHO[14]). The diseases presented in the letter are either not proven to be related to wind energy (to date the risk of vibroacoustic disease has been documented for specific professional groups, e.g. employees of space aviation programmes[15]) or deemed non-existent by the medical environment (the wind turbine syndrome has never been included on an official WHO list of diseases[16]as a theory not supported by reliable research[17]). However, they are a permanent element of the discourse of the technology’s opponents, repeated despite being many times invalidated in scientific papers and independent reports.[18],[19],[20]Renewable technologies contribute to increased quality of the environment, what directly postiviely affects the long-term population health. Anxiety concerning long-term impact on local communities is furthermore dispelled by experiences of other European countries with higher number of such installations.This proves that wind energy investments may be a benefit for the local community and the environment, contributing to sustainable development of the state’s energy system.

In the Polish legal order wind farms may be built on the basis of the so-called outline planning permission or a full planning procedure (adoption of a local spatial development plan or amendment of an existing plan). Construction on the basis of an outline planning permission is possible only for areas without a valid local spatial development plan; therefore, pursuant to this procedure it is impossible to build a wind farm on an area with a different purpose, e.g. residential, for such purpose is laid down in a local spatial development plan. PWEA is recommending construction of wind farms on the basis of a full planning procedure, for it enables broader public participation in the EIA procedure and more sustainable regional development.

Contrary to common opinions, wind farms being built are often subject to binding minimum distances from residential development. Such restrictions may stem from provisions of local spatial development plans and are often included in the environmental decision for a particular investment. Each time they stem from an analysis of a specific case and are binding for the investor. Similarly, the requirement to comply with allowable noise level standards mentioned in the open letter is binding. The letter does not include an important information that the planned modifications to the relevant Regulation are to apply to line investments (roads and railroads) only, hence acoustic standards for all other investments, including wind farms, will not be relaxed. Furthermore, noise regulations are the most common method to regulate wind farm location in European countries deemed to be the most advantageous for the environment and humans, for it enables adaptation of the investment to the characteristics of a particular site.

We think that the parliamentary draft of an act imposing the minimum distance between wind farms and residential development of 3 km recommended by the Safe energy (draft Act amending the Building Code and the Spatial Planning and Development Act) [21] shall not be proceeded further. It is subject to numerous legal defects and, most importantly, undermines the currently applicable EIA system – its implementation will result in a very difficult to estimate financial burden for regional and state budget through retroactive effect of certain provisions[22]. Adoption of this regulation would preclude the construction of new wind farms in Poland, hence it would eliminate a substantial part of the national renewable energy market.

This would not only completely preclude the development of new wind energy sources, but also forfeit the local communities’ opportunity to gain additional revenues and new jobs. We already notified the Speaker of the Sejm, Ewa Kopacz, and particular ministries thereof in a separate notice, which presented the actual financial, social and environmental effects stemming from implementation of the proposed provisions. One of the consequences with rather severe financial effects is that the regulations would preclude the achievement of mandatory targets in the area of the production of energy from renewable sources by 2020 by Poland – without substantial wind energy development this will not be possible[23]. Furthermore, we would like to stress that achievement of these obligations does not contradict the recommendations stemming from ratification of the Landscape Convention, for green technology development not only does not interfere with, but actually favours long-term landscape protection from more burdening types of activity: after disassembly of a wind farm by the investor, who is usually obligated to do so after decommissioning by the environmental decision, the landscape is restored to its original condition. The synergy between RES development and landscape protection is demonstrated by countries which also ratified the Landscape Convention while being the leading producers of wind energy in Europe (e.g. Spain and Denmark).

We regret that certain organisations whose declared statutory goal is environmental protection exhibit illegitimate scepticism towards wind energy technology, which is less burdening and safer for the environment and humans than conventional energy. Wind energy is equivalent to safe energy. We think that the society is being mislead on a massive scale by publication of false and unverified information without quoting any sources while it deserves access to reliable knowledge concerning these issues, which we are ready to provide and promote. We are convinced that there exists an urgent need for a broad, governmental educational action featuring renewable energy sources to increase common knowledge concerning these sources and create a space for conscious social acceptance for RES technologies – to the advantage of the Polish society and the common good, i.e. the environment.

Krzysztof Prasałek
President of the Board