The members of Working Group 3 “Environment, Climate Change and Energy Security” of the Ukrainian National Platform of the Civil Society Forum of the Eastern Partnership (UNP EaP CSF) and Working Group 5 “Energy, Transport, Environment and Climate Change” of the Ukrainian side of the Ukraine-EU Civil Society Platform (US CSP) supported the appeal for protection of the Carpathian ridge with an international nature conservation status – the Borzhava mountain meadow – from a wind power plant being constructed on it.
The appeal was prepared Environment People Law (EPL)/Екологія – Право – Людина (ЕПЛ) (UNP WG3 member).
To: the President of Ukraine
Minister for Environmental Protection
and Natural Resources of Ukraine
the Cabinet of Ministers of Ukraine
With a motor grader through the green heart of the Carpathians or how “green” energy destroys the national treasure – the Borzhava mountain meadow
The appeal for protection of the Carpathian ridge with an international nature conservation status – the Borzhava mountain meadow – from a wind power plant being constructed on it.
The preparatory works, in particular the laying of a dirt road for construction of a wind power plant, are already in progress on the territory of the Borzhava mountain meadow, which has already caused destruction of significant fragments of high-altitude grass and soil cover as well as surface erosion processes.
The contruction project envisages installation of foundations with a diameter of up to 18 meters and a depth of 4 meters for 34 wind turbines, as well as access roads, underground power lines and a power transmission substation.
Further implementation of the project will lead to much more extensive destruction and adverse consequences such as degradation and loss of habitats for rare species of animals and plants. Construction of wind turbines envisages application of heavy equipment and excavators to build pits for the foundations. Due to a significant number of days with adverse weather conditions, there will be an additional impact and risk of increased erosion processes. The areas of location of wind turbines cover relatively small territories but transportation of large-sized spare parts, placement of construction equipment and temporary storage of construction materials involve much larger territories than those needed only for turbines. This leads to large-scale destruction of the until recently undisturbed landscapes and natural territories. Construction of wind power plants in the mountains implies construction of special roads for delivery of integral parts for wind turbines.
When developing the environmental impact assessment report, the developers deliberately underestimated the impact on natural ecosystems and provided inaccurate information regarding potential destruction of rare species and biotopes on the Borzhava mountain meadow.
1. Value of the Borzhava mountain meadow
The Borzhava mountain meadow is a mountain massif on the Polonyna Ridge in the Ukrainian Carpathians. The length of the massif is about 30 km, the maximum height is 1681 m (Mountain Stij). It is a nature conservation area of international importance, an object of the European Emerald Network approved by the Standing Committee of the Bern Convention. It is part of the environmental network of the Ukrainian Carpathians. In this territory, scientists discovered 94 species of birds, including 8 species listed in the Red Book of Ukraine, 9 species of bats, 21 species of vascular plants listed in the Red Book of Ukraine, and 22 species of invertebrates. The Borzhava mountain meadow is part of the international migration route of a number of bird species including rare ones that are protected by national and international legislation, in particular common crane, black stork, hen harrier, marsh harrier, osprey, black kite, lesser spotted eagle, greater spotted eagle. On 25 September 2018, as part of the autumn migration, a mass flight of common cranes heading to their wintering grounds was observed throughout Europe. On that day, a mass flight of common cranes was also recorded over the Borzhava mountain meadow, totallying to about 3,000 cranes in more than 30 flocks flying there that day.
Borzhava slopes are home to unique ancient and primeval forests, which slow down the development of “flash” floods for the rivers of the Tisza basin, in particular, the Borzhava, the Latorytsa, the Repinka and others, which are known for their suddenness and the capacity to flood significant territories of settlements in Zakarpattia region. The slopes of Borzhava differ in their steepness from the surrounding mountains. There is a risk of intensification of this type of flooding (and, accordingly, a threat to settlements) in case of felling of the meadow-adjacent forests.
The territories covered with old-growth forests and primeval forests on the spurs of the Borzhava mountain meadow now amount to about 4,000 hectares. This is one of the largest areas of concentration of this type of forests in Ukraine. Only a third of these forests are now under effective protection. These are places where you can often see the tracks of a brown bear, a lynx, a wolf and a forest cat. The uniqueness of these terrains is difficult to overestimate.
There are 8 Ukrainian protected areas located around the Borzhava ridge and directly on it. Each of these objects of the nature reserve fund was created for the purpose of protecting natural complexes, as well as rare species of flora and fauna.
Also, here is located the planned protected area rfor which the protected status has been reserved by the decision of the authorities: this is the planned national nature park “Zhdymyr” with an area of 21,600 hectares (Decision of the Zakarpattia Regional Council No. 695 of December 26, 2003 that approved the Program for the perspective development of the protected areas and environmental network in the Zakarpattia region for 2006-2020). The justification for creation of a landscape reserve of local importance “Zelenytsia” has been submitted to the Zakarpattia Regional State Administration.
2. Risks for the Borzhava mountain meadow
The wind power plant construction on the territory of the Borzhava mountain meadow will have a significant adverse impact on the ecosystems of the Borzhava ridge and on all components of nature (geological structure, soils, water, vegetation, animal life, topography, as well as rare species of flora and fauna and habitats protected on the territory of the Emerald network), which is the reason to define such an action as unacceptable.
Impacts on the environment may appear during any of the phases of the wind power plants projects: starting ffrom the contruction (mechanical damage to vegetation, soils, geological structure, accidental or emergency contamination of water and soil with fuel, lubricants or transformer lubricants during construction) to operation (noise, blade flickering, electromagnetic radiation, vibration, visual impact due to landscape changes, fire risks, ice detachment from blades), as well as during restoration or decommissioning phases. The consequence can be temporary or permanent impacts that are different in radius of action, as well as the cumulative effect that is a combination of various impacts. Decommissioning and dismantling of a wind power plant after the end of its operational life will lead to disturbances similar to those that occur during the construction of a wind power plant. Such impacts are particularly significant within the boundaries of protected areas and international nature protection territories.
In addition to the destruction of habitats, there are threats of collision of birds and bats with various parts of wind turbines or with other structural elements of wind power plants, their injury and death. Other impacts include disturbance of animals and their migration to other territories, loss of habitats due to visual, noise and vibration impacts, as well as increased human activity during construction works and maintenance, easier access to the area because of the road construction. Another risk is so-called barrier effect, which is disruption of communication between places of feeding and rest, that will force birds or bats to change the direction of movement, in particular during migrations, as well as during flights in the area2.
The Ukrainian Carpathians are flysch mountains that are subject to strong water erosion. Earthworks under the wind power plants will cause massive erosion processes, which will create a high risk of landslides and mudslides during heavy rains and downpours. The Borzhava mountain meadow is the catchment area of the main tributaries of the Tisza River – the Latorytsia and the Borzhava rivers, as well as the protected Osa river. Violation of the vegetation cover on large areas of marshland will contribute to rapid formation of floods in the valleys of these rivers during rainy seasons, as well as to dehydration of catchments and shallowing of these watercourses during drought.
As an example, we provide a photo of the first concrete foundation under the Nyzhniovoritska wind power plant to better illustrate what will happen on the Borzhava mountain meadow. The area of impact zone resulting from preparation of one concrete foundation is about 2 hectares.
Also, the developers did not take into account the information that the Borzhava mountain meadow contains particularly valuable soils of the Carpathian province the list of which was approved by the Order of the State Committee of Ukraine on Land Resources No. 245 dated 06.10.2003.
3. Green energy
The use of wind energy is generally considered to be an environmentally friendly technology, “green energy”. However, if neglecting environmental norms and basic laws of the functioning of natural complexes, selecting sites for construction of wind power plants based only on wind indicators and simplicity of land acquisition registration procedure, then construction of wind power plants can lead to negative consequences and be a threat for nature.
By choosing a wrong location for a wind power plant, the beautiful idea of “green” energy can be completely destorted by the destructive impact of wind power plants on wildlife. This is beacuse all components of nature suffer including geological structure, soils, water environment, plant and animal world, topography of the territory, climate. This also entails a violation of Ukrainian legislation and international environmental agreements.
Construction of wind power plants should be performed outside protected areas, protected habitats, and outside migration routes of bats and birds and their key habitats.
The likelihood of impact factors overlapping, their permanent, temporary and cumulative nature must necessarily be a part of environmental impact assessment and strategic environmental assessment. Before construction of wind power plants, thorough studies of the effects on natural complexes and all their components must be carried out. If there are already operating wind turbines or other economic complexes in the region, their cumulative impact on natural complexes and migration routes, the probability of a barrier effect must be assessed.
The potential consequences of constructing wind power plants should be considered in each specific case separately and independently. Because the types and extent of impacts depend on a number of factors unique to each area, results of one study cannot in any case be extrapolated to other areas. A separate study must be conducted for each new project of a wind power plant construction.
Environmental impact assessment (EIA) is a key tool of ensuring that informed decisions are adopted and it must be conducted by professional and competent scientists. During the EIA for wind power plant construction projects, it is important to conduct basic field studies lasting at least one year, to analyze various scenarios of possible developments, to model risks and probabilities of adverse natural phenomena, to study innovative mitigation measures, as well as the cumulative effects of wind power plants with all planned or existing facilities that can have adverse impact on the environment.
The construction of a wind power plant and its infrastructure on the Borzhava mountain meadow is an activity incompatible with nature conservation, the goals of the international nature conservation territory of the Emerald Network, the purpose of functioning of natural protected areas and will destroy habitats of rare, endangered and endemic species of animals and plants, as well as the territory, which for centuries was used for development of animal husbandry and collection of non-wood products (blueberries). This helped a dozen significant local communities to survive in the most stormy years of our history and to preserve ethno-cultural heritage.
The construction of a wind power plant on the territory of Borzhava mountain meadow is unacceptable and must be stopped.
In view of the above, we request the following:
- To consider another territorial and project alternative in the territories that are located outside the international and national nature conservation areas, and outside the mountain ranges of the Ukrainian Carpathians, which are the property of the Ukrainian people and territories of exceptional natural value and should not be destroyed for the purpose of obtaining profits from green energy. We remind you that the main idea of green energy at its core is preservation of nature, not its destruction.
- To initiate discussion of location alternatives for wind power plants with the participation of Turkish investors,environmental protection experts and research institutions.
- To stop preparatory construction works for erection of a wind power plant on the Borzhava mountain meadow.
- To support creation of a nature protection area of national importance on the Borzhava mountain meadow and around it in order to meet Ukraine’s European integration obligations.
We are thank to Environment People Law (EPL)/Ecology – Law – Human (EPL) (members of WG3 UNP) for the analysis of the draft law and the preparation of the draft appeal.