GUIDELINES FOR OBSERVING THE DEFENCE FORCES’ ACTIVITIES IN WIND POWER BUILDING
In accordance with section 24 of the Land Use and Building Act (132/1999), in all land use planning, national land use objectives must be taken into account in a way that promotes their implementation. According to the national land use objectives which came into effect on 1 April 2018, the needs related to the society’s comprehensive security, in particular national defence and border surveillance must be accounted for and these areas of activity must be secured adequate regional development conditions and viability.
According to section 4a of the Land Use and Building Act, land use planning shall secure the development needs of national defence, border security and border surveillance, civil defence and security of supply and ensure that the ability to operate of the actors in charge will not be weakened.
According to section 9:1 of the Land Use and Building Act, a land-use plan must be founded on planning which is based on the assessment of significant impacts of the plan when implemented, the necessary studies and reports included. The examination of the impacts of a land-use plan must account for the purpose and objective of the plan.
In accordance with section 9, slubsection 3 of the Land Use and Building Act, in case a land-use plan is drafted to implement a project referred to in section 3 of the Act on the assessment procedure of environmental impacts (252/2017), the environmental impacts of the project may be assessed in conjunction with the land-use planning instead of following the procedure under Chapter 3 of the Act. The assessment of environmental impacts is provided for in the Act on the assessment procedure of environmental impacts (252/2017).
As laid down in section 33, subsection 1 of the Land Use and Building Act, a building restriction is in force in areas designated by the regional plan as recreation or protection areas, areas designated for purposes of the Defence Forces or the Border Guard and areas for transportation or technical service networks. The area covered by building restrictions may be increased or decreased by a special order in the plan.
The most significant and extensive impacts of wind turbines fall on the Defence Forces’ territorial surveillance sensors. This may result in extensive negative effects on the Defence Forces’ conduct of its statutory task of territorial surveillance provided for in the Act on the Defence Forces 551/2007, Territorial Surveillance Act 755/2000 as well as Aviation Act 1194/2009. The Bay of Bothnia compensation area is covered by the Act 490/2013.
Defence Forces’ statements regarding wind power
The Defence Forces issues statements regarding land-use planning. The FDF also provides separate statements regarding the impacts of wind power projects on sensors. In some cases, a statement involving the environmental impacts assessment (EIA) procedure is also required.
The Defence Forces Logistics Regiment issues statements regarding land-use planning and the EIA procedure. The Defence Command Operations Division issues statements on wind power’s impacts on sensors.
This document provides instructions for requesting a statement regarding wind energy impacts on sensors, which should be done early in the planning stage of the wind power project.
In respect of projects, the Defence Forces provides, on request, separate statements with regard to a need to conduct a more specific examination into any impacts a wind energy project might have on territorial surveillance sensors, and the acceptability of a wind energy project from the Defence Forces’ perspective. If necessary, a calculation of the project’s adverse impacts on the sensors must be commissioned from VTT. On the basis of more specified data obtained on the planned wind turbines, (wind turbines’ maximum heights, location coordinates and numbers), the Defence Command (Operations Division) assesses whether a more specified investigation is required. The investigation of the impacts of the wind turbines to be constructed on territorial surveillance sensors is the responsibility of the wind power developer or land-use planner. If an impact analysis is needed from VTT, it should be achieved no later than in the detailed planning phase.
Without exception, a separate statement must be requested from the Defence Command regarding wind turbines with a height of more than 50 metres (total height from ground level) over the entire area of the municipality.
The Defence Command must be requested a statement also regarding small wind turbines with a height of less than 50 metres (total height from ground level) in case the property on which the wind turbine is intended to be constructed abuts an area used by the Defence Forces.
In addition to the Defence Forces, a statement by Suomen Erillisverkot Oy regarding land-use planning is also required
at [email protected] (non-classified) and securemail.tuve.fi (classified).
To be considered with regard to the location of wind turbines
- at least 40 km from radar
- can be considerably larger depending on altitude differences and direction
- at least 4 km from the border of the area used by the Defence Forces
- at least 12 km from the centre of the runway of the emergency landing place
- in planning wind power areas, account must be taken of the aviation danger area EFD 300 on the eastern border and the CBT / CBA training area between Finland and Sweden. More detailed information and coordinates of both are available in the AIP manual of aviation with a Google search. There are no positive statements for wind turbines on either.
Requests for statement
Coordinates of wind turbines in an Excel table (ETRS- TM 35/FIN)
- N in 7 figures, E in 6 figures (no decimals)
- e.g. N 6901520 E 311796
A filled in PDF form (request for statement) not secure
- enables copying information for writing a statement
- Maximum size of attachments is allowed to be 20Mt
A request to Suomen Erillisverkot Oy (former STUVE) at the same time when sending a request to us ([email protected] )
A notification if a project gets cancelled
- allows for new projects to be initiated in the area concerned
Enquiries to the [email protected] email, not to the Registry Office
- Without exception, requests for statement to the Registry Office
The Regions establish and make plans for areas suitable for them for wind power construction in regional land use plans.
However, the Defence Command must be requested a statement regarding any wind power project without exception regardless of whether the project concerned is within a municipality’s wind energy area or elsewhere in the municipality.
The Defence Command obtains specified data on the heights, numbers and precise coordinates of the planned wind turbines when the wind power developer submits a request for a statement to the Defence Command. Based on these data, the Defence Command issues its statement.
Since 2020, the statements regarding wind turbines granted by the Defence Forces have been issued for a fixed period of time. When the fixed-time period of five years is about to expire, it is possible to apply for an extension for the period of validity of a statement. An extension may be granted for a period of five years from the expiry of the validity of the statement. A free-form request for extending the period of validity of a statement must be submitted to [email protected]. (The application does not need to be sent to the Registry Office.)
Extension for a statement must not be applied for until in the year the statement expires; extension for statements due to expire in coming years is not granted in advance. In case a statement for a project involving a modification or modifications has been issued after 2020, the five-year validity of the statement is counted from the date of signature of the modified statement. In case the latest statement regarding a project has been issued before 2020, and there is no mention in the statement involving a five-year validity period, the statement remains valid for an indeterminate duration, and one is not obligated to apply for an extension for it.
Changes to a wind power project
If there are plans to increase the height of wind turbines intended to be constructed by more than 10 metres, to increase their number or to shift their location by more than 100 metres compared to the prior information based on which the Defence Forces (Operations Division) has issued a statement for the approval of the project, the project developer must ask the Defence Forces for a new approval statement.
By seeking a statement early in the planning stage will strengthen the project’s chances of success in subsequent administrative procedures as concerns the adequate assessment of its impacts on the Defence Forces.
Also in case the changes are smaller than described above, the Defence Command Operations Division should be notified of these changes to make sure that the Defence Command Operations Division possesses the correct coordinates. A new statement is not required for the relocation of a wind turbine by less than 100 metres, excluding projects assessed by VTT.
Subsequent work
Account must be taken of any Defence Forces cable lines in the area and its vicinity when carrying out excavation and construction work both on land and at sea. The location of any cable lines should be determined a minimum of 10 working days before the start of the intended construction work.
Cable screens for the Defence Forces are ordered from Johtotieto Oy. Johtotieto Oy provides guidance to excavators and constructors.
Contact information for ordering cable screens:
Johtotieto Oy
Seutulantie 1
04410 Järvenpää
Tel 0800 12600
[email protected]
https://johtotietopankki.fi
A statement involving cables should also be requested from Suomen Erillisverkot Oy via the customer service ([email protected])
Any costs incurred from the transfer of existing cabling routes, protection of cables for the duration of construction or other changes due to the building of wind power turbines are payable by the party which causes the change.
Contact persons
Requests for statements involving wind power projects (see paragraph 2 of this guidelines document) should be addressed to the Defence Command at [email protected] or Defence Command, P.O. Box 919, 00131 Helsinki. In the Defence Command, matters related to wind power are processed by the Operations Division. Additional information/enquiries (excluding requests for statements) at: [email protected]
Request for statement forms (Finnish, Swedish and English):
https://puolustusvoimat.fi/tuulivoimaloiden-lausuntoprosessi
https://puolustusvoimat.fi/sv/forsvarsmakten-ger-utlatanden-om-vindkraftsprojekt
https://defenceforces.fi/wind-farm-consultation-prosess
Requests for statements regarding land-use plans involving a wind power project and the participation and assessment scheme and environmental impacts assessment (EIA) procedure and meeting invitations should be sent by email to:
[email protected] or 1st Logistics Regiment’s Headquarters (1LOGRE), P.O. Box 1080, 45101 Kouvola, or
[email protected] or 2nd Logistics Regiment’s Headquarters (2LOGRE), P.O. Box 1000, 20811 TURKU, or
[email protected] or 3rd Logistics Regiment’s Headquarters (3LOGRE), P.O. Box 14, 41161 TIKKAKOSKI