Letters / A risk too great: why the Energy Isles electricity generation licence must be denied
The consented Statkraft/Energy Isles Wind Farm in Yell, requires urgent public scrutiny. Statkraft, the company developing the project that was consented by the Scottish Government in October 2023, has now applied for an electricity generation licence under Section 6(1)(a) of the Electricity Act 1989. However, significant and unresolved risks to Gossa Water, the loch that provides tap water for ~950 residents of Yell, make granting this application wholly unacceptable.
Despite the statutory requirement in Annex 2, Point 41 of the decision letter, which states, “There shall be no Commencement of Development unless and until a Drinking Water Protection and Treatment Plan has been submitted to and approved in writing by the Planning Authority in consultation with Scottish Water. The Drinking Water Protection and Treatment Plan shall set out measures to protect water quality and quantity,” Statkraft has yet to submit the required plan. Without including a post-incident remediation plan in it, there is no assurance of safeguarding Gossa Water during construction and operation. Ofgem should refuse a licence to generate electricity until this plan has been submitted and approved in which there is a post-incident remediation plan.[i]
Preventative measures are not enough
Statkraft’s reliance on extensive preventative measures such as buffer zones, silt fences, and controlled water discharge fails to address the elephant in the room: what happens if these measures fail? Experience from other developments, such as the Viking Wind Farm, has shown that preventative measures are not infallible.[ii] Without a solid post-incident remediation plan, the consequences could be very serious. The lack of detailed strategies to tackle heavy metal contamination of the Gossa Water from disturbed peat, for instance, is a glaring omission.
At a public meeting in Sellafirth in June 2023, a local crofter raised concerns about Gossa Water contamination. Statkraft’s response was to say that £100,000 had been set aside to buy bottled water in the event of an emergency. Such a proposition is not only impractical but highlights a worrying lack of commitment to genuine water protection. Providing bottled water is not a solution; it is an admission of unpreparedness.
A pattern of environmental negligence?
Statkraft’s environmental track record further compounds these concerns. In 2022, their operations in Norway resulted in a damaging sludge spill in the Surna River, devastating 30 km of critical salmon habitat. Local authorities labelled it potentially the worst sludge spill in Norwegian history, raising serious questions about Statkraft’s ability to manage environmental risk responsibly.[iii]
Adding to these concerns, Statkraft faced legal action from Indigenous communities in Chile for allegedly advancing hydropower projects without proper consultation. Such examples reinforce the argument that Statkraft cannot be trusted to operate without stringent oversight and clear accountability measures.[iv]
A disproportionate risk for minimal gain
Proponents of the wind farm argue that it will contribute to reducing the UK’s carbon emissions. However, the reality is stark: the UK accounts for only 1.1% of global greenhouse gas emissions, and the destruction of an area of peatland in pristine or near natural condition, far outweighs any marginal climate benefits. The carbon storage capacity of functioning peat bogs, which have been sequestering carbon for over 5,000 years, cannot be replicated by any mitigation measure Statkraft offers.
The trade-off is clear: Yell’s residents face potential environmental and public health risks, while the purported climate benefits are questionable at best, so even from a utilitarian point of view, the argument is poor.
Binding commitments are needed
It is deeply concerning that Statkraft has not made any binding statutory guarantees for what will be done to keep tap-water safe in the event that Gossa Water becomes polluted during the wind farm’s construction and operation. The Scottish Government requires that no work can commence without an approved Drinking Water Protection and Treatment Plan, yet this condition remains unmet. If Statkraft is serious about their environmental responsibilities, they must provide legally binding commitments ensuring no pollution will occur.
The case for refusal
For these reasons, granting an electricity generation licence at this stage would be irresponsible. This objection therefore calls for the following actions before any licence is considered:
- Submission and approval of a Drinking Water Protection and Treatment Plan, as required by the Scottish Government.
- Detailed and binding remediation measures, including heavy metal removal strategies.
- Accountability measures, requiring Statkraft to provide statutory guarantees against pollution.
Approving the licence in the absence of these fundamental safeguards would not only disregard regulatory requirements but also put public health and the environment at risk.
The deadline to submit objections to Ofgem is Friday, 24 January. Ofgem have asked for comments on this application to be made by emailing: licensing@ofgem.gov.uk.
Adrian Brockless
Burravoe
Yell
[i] All documents relating to the approval and conditions of approval of the Statkraft/Energy Isles windfarm in Yell, Shetland can be found here on the Energy Consents Unit webpage ECU00001844: https://www.energyconsents.scot/ApplicationDetails.aspx?cr=ECU00001844
[ii] https://www.shetnews.co.uk/2020/09/23/viking-vows-to-implement-better-water-management-measures/
