Wind power in forests: the SRFB's position
In view of the growing number of wind farm projects in woodland areas, the SRFB has taken a stance with a opposition to planting and therefore to the exclusion of any new installations. Unfortunately, the Commission notes and deplores the fact that wind turbines have already been installed in woodland and that projects to install them are currently being analysed. It is against this backdrop that it presents objective arguments for exclusion in its memorandum, which we invite you to pass on to the promoters of wind farm projects, the authorities and the owners of the plots of land concerned.
Wind power in the Belgian forest
Position of the Royal Forestry Society of Belgium (SRFB)
- Introductory note
Regional legislation allows the installation of wind turbines in forests under certain conditions. In view of the increasing number of wind farm projects already underway, SRFB has decided to clarify its position on the subject. To do so, it has analysed the relevance of installing wind turbines in forests and their impact on the forest environment and its ecosystem services.1.
The heritage aspects (advantages or disadvantages for the owner of the plots of land where the wind turbine is located and for neighbouring owners) do not fall within the SRFB's scope of investigation; they are therefore absent from its position. - General context for energy policy and transition
A number of European, federal and regional policies set specific targets for the energy transition. For example, the European Union has set itself a target of 32% of renewable energy by 2030, combined with a reduction in greenhouse gas emissions (-40% in 2030 compared with 1990). At both federal and regional level, feasibility analyses are currently being carried out into the possibilities for improving energy efficiency (with a view to achieving a "zero emissions" target by 2050).
Without considering the strong likelihood that these objectives will be reinforced in the short term, these few elements have been taken into account in the SRFB's analysis of the wind farm in the forest dossier.
Replacing fossil and nuclear energy production with renewable energy production is now an obligation, not a choice. The narrowness of the Belgian territory and the density of housing are constraining realities in terms of the availability of space to decide on a coherent distribution of the different renewable energy productions. - General opinion on renewable energies
In this context, SRFB is aware of the strategic importance of the country's energy autonomy, but attaches equal importance to prioritising and implementing all possible actions to reduce energy consumption globally.
It also stresses the need to diversify renewable energy sources (hydroelectric, solar, wind, biomass, etc.) with a global vision for optimising the quality of use of rural areas.
Forest covers 23% of Belgian territory (11% of Flemish territory and 33% of Walloon territory).
While public authorities require forests to play their part in the distribution of renewable energy sources, the SRFB is calling for the primary roles of forests in terms of ecosystem services (including wood production), which are supported by biodiversity, not to be undermined and for their ecosystems to be preserved. - SRFB analysis and position on wind power in forests
- Wind energy produced in forests is not one of the ecosystem services provided by forests. The SRFB therefore considers that it has no place there.
- Wind turbines installed in forested areas or near wooded areas have an impact mainly on avifauna and bats (chiropterofauna) and, potentially depending on the sites chosen, on water. It should be noted that the impact can be significantly reduced if certain installation criteria are met.
- In some parts of the country, forests are the last large areas untouched by urbanisation or industrialisation. The siting of wind turbines has an impact on the landscape and the tranquillity of these unspoilt areas.
In conclusion, the SRFB is not in favour of the construction of wind turbines in forests, which should be reflected in the exclusion of all new installations.
Unfortunately, it notes and deplores the fact that wind turbines have already been installed in forests, and that projects to install them are currently being analysed without a strict and coherent framework being defined. In this context, if the public authority cannot avoid the deployment of wind turbines in forests, the parameters specified in the appendix to this opinion must imperatively be respected.
Appendix to SRFB's position on wind power in forests
Imperative parameters to be taken into account in the case of a wind farm project in a forest or on the edge of a forest
The SRFB calls on wind farm project developers, the authorities and the owners of the land concerned to take the following points into account when siting wind turbines in wooded areas and/or on the edge of wooded areas.
- Wind farm exclusion zones :
- Automatically subtract historically protected woodland areas from the areas available for wind turbine siting2by Natura 2000, by Sites of Great Biological Interest (SGIB) or "Speciale Beschermingszones" (SBZ-habitats/vogels), hydromorphic areas, etc.3In addition to these unavailable areas, the impact studies will have to exclude, among other things, areas that are automatically unsuitable for profitable wind turbine production, and bird migration corridors. In addition to these unavailable areas, the impact studies will, where appropriate, have to exclude, among other things, office areas that are not conducive to profitable wind turbine production, bird migration corridors or areas subject to major operating restrictions.
- Define protective perimeters around these exclusion zones, if not already legislated for locally.
- Limiting the impact on avifauna and chiroptera :
- To significantly reduce the impact on avifauna and bats, the wind turbine must be configured to allow a minimum clearance height of 35 m between the canopy and the bottom of the blade. At present, the height of the wind turbine must therefore be at least 180 m. This is a key parameter that must be respected.
- Limit the number of wind farms in any one area in order to minimise the impact on avifauna and bats.
- At the scale of the wind farm project, maintain a wooded state and significantly reduce any open space in the vicinity of the wind turbines in order to reduce the attraction of the open environment created for avifauna and bats. More specifically, clear-cutting in the vicinity of the wind turbines should be avoided by favouring continuous cover forestry.4. Reforestation around the wind turbine once it has been built should be carried out as quickly as possible. Similarly, any wind turbine installed in an agricultural or open environment should be at least 100 m away from forest edges.
- Take into account and implement all technically feasible measures to limit the impact of wind turbines on avifauna and bats (flanging, etc.).
- Impact on other forest ecosystem services :
- Pay particular attention to the impact of the siting and construction of infrastructure (wind turbines and/or associated roads) on the various ecosystem services linked to water. Exclude hydromorphic zones as mentioned above. Carry out a hydrogeological study to ensure that the planned infrastructure does not interfere with the circulation of surface and groundwater.
- Implementing specific measures to limit the disturbance caused by increased traffic from forest users. The attractiveness of the wind turbines to the public and the improvement of the roads must not increase the inconvenience caused by forest user traffic beyond the pre-existing situation. In this context, the impact of opening up the roads to forest users will have to be studied on a case-by-case basis, possibly with access restrictions to ensure the peace and quiet of sensitive areas.
- Use all technical measures to reduce noise pollution from wind turbines in order to maintain the tranquillity of the forest environment.
- Systematically carry out an impact assessment on the main recognised and measurable ecosystem services. Particular attention will be paid to protected species present on potential sites.
- Compensation and restoration measures :
- Where damage caused by the siting of wind turbines cannot be avoided or sufficiently mitigated, proportionate compensation will be provided on a case-by-case basis.5 could be envisaged to remedy these problems. As far as the forest is concerned, the area used up by the installation of wind turbines must be compensated for by new areas that promote multifunctionality in a sustainable way, with monitoring and maintenance over time. This could include measures to promote the production and use of wood, to improve habitats for biodiversity, to create a balance between the forest and large fauna, to welcome the public and to create infrastructures to protect water and soil.
- Each wind farm project must be designed and built with a view to total reversibility at the end of its operational life. To achieve this, the developer will be required to lodge an irrevocable guarantee of a sufficient amount and duration to ensure that the site is fully restored once the turbines have been dismantled.
Position approved by the Board of Directors on 11 June 2019
- Ecosystem services represent the contribution that ecosystems make to human well-being. In Wallonia, they include production services (provision of food, fuel and materials), regulation services (air and water purification, flood protection, pollination, carbon storage, etc.) and cultural services (heritage, outdoor recreation, etc.). Definition taken from État de l'environnement en Wallonie (2018).
- Forest areas protected by their historicity correspond to areas of deciduous woodland that have been continuous for more than 250 years (Ferraris map). These are forests that may have been exploited (thinning, coppicing, etc.) but never cleared. They have a higher specific biodiversity than forests replanted after clearing.
- Hydromorphic areas include springs and seepage areas near wells, peaty, paratourbous and hydromorphic soils with a permanent water table, as determined by the Belgian soil map.
- Continuous cover silviculture" aims to harvest timber while permanently preserving a wooded state and ensuring continuous regeneration under mature trees over time.