Landsnet · 2017. 9. 5. · Author: ï¿½ï¿½Rut Kristinsdï¿½ttir Created Date: 9/5/2017 10:07:01 AM

HIGH VOLTAGE TRANSMISSION LINES (220 KV) FROM KRAFLA AND

ÞEISTAREYKIR TO BAKKI BY HÚSAVÍK. UNDERGROUND CABLE (132

KV) FROM BJARNARFLAG TO KRAFLA; NORÐURÞING,

SKÚTUSTAÐAHREPPUR MUNICIPALITY AND ÞINGEYJARSVEIT

MUNICIPALITY

THE CONCLUSIONS OF THE ICELANDIC NATIONAL PLANNING AGENCY ON THE

ENVIRONMENTAL IMPACT ASSESSMENT (EIA) (24TH NOVEMBER 2010)

This is an English translation. The original Icelandic text, is the authoritative text. Should

there be discrepancy between this translation and the authoritative text, the latter prevails.

Unofficial translation

2

Contents

1 INTRODUCTION ............................................................................................................................... 3

1.1 COMMENTS FROM THE ICELANDIC NATIONAL PLANNING AGENCY ...................................... 3

2 IMPLEMENTATION AND OBJECTIVES .............................................................................................. 6

2.1 CONNECTED CONSTRUCTION ................................................................................................ 10

2.2 OTHER OPTIONS .................................................................................................................... 12

3 RESULTS OF THE ENVIRONMENTAL IMPACT ASSESSMENT (EIA) .................................................. 14

3.1 CHARACTERISTICS AND EXTENT OF ENVIRONMENTAL EFFECTS .......................................... 14

3.2 VISUAL IMPACT AND EFFECTS ON LANDSCAPE, PROTECTION, OUTDOOR RECREATION AND

TOURISM ........................................................................................................................................... 15

3.3 EFFECTS ON GEOLOGICAL FORMATIONS .............................................................................. 24

3.4 EFFECTS ON CULTURAL RELICS .............................................................................................. 28

3.5 EFFECTS ON VEGETATION ..................................................................................................... 29

3.6 EFFECTS ON BIRDLIFE ............................................................................................................ 32

3.7 EFFECTS ON HYDROLOGICAL CONDITIONS ........................................................................... 33

3.8 EFFECTS OF ATMOSPHERIC NOISE AND ELECTRIC AND MAGNETIC FIELDS .......................... 35

3.9 STATUS OF PLANNING AND LICENCES ................................................................................... 36

4 THE ICELANDIC NATIONAL PLANNING AGENCY’S CONCLUSIONS ................................................. 38


3

1 INTRODUCTION

1.1 COMMENTS FROM THE ICELANDIC NATIONAL PLANNING AGENCY

Landsnet submitted an IEIS on high voltage transmission lines (220 kV) from Krafla and Þeistareykir

(pronounced Theistareykir) to Bakki by Húsavík and an underground cable (132 kV) from Bjarnarflag

to Krafla, Norðurþing (pronounced Nordurthing), Skútustaðahreppur Municipality and Þingeyjarsveit

(pronounced Thingeyarsveit), to be assessed by the Icelandic National Planning Agency, under the

Environmental Impact Assessment Act no. 106 / 2000 „with subsequent amendments”.

The construction project and ‘Initial Environmental Impact Statement (IEIS)’ were publically advertised

in Lögbirtingablaðið (the Official Gazette) and the Fréttablaðið and Morgunblaðið newspapers on the

30th of April, 2010 as well as Mýflugan and Hlaupastelpan on the 28th of April, 2010 and in Skarpi on

the 29th of April, 2010. The IEIS was available from the 30th of April until the 14th of June, 2010 at

the local office of the Skútustaðahreppur Municipality and Þingeyjarsveit Municipality, in the

administrative building for Norðurþing in Húsavík and at the library in Húsavík. The report was also

available at the National University Library of Iceland and at the Icelandic National Planning Agency.

The IEIS was also accessible on the internet: www.mannvit.is, www.landsnet.is and www.the Icelandic

National Planning Agency.is. The Icelandic National Planning Agency requested the opinions of

Norðurþing, Skútustaðahreppur Municipality, Þingeyjarsveit Municipality, Iceland Fire Authority, the

Icelandic Tourist Board, the Archaeological Heritage Agency of Iceland, the Public Health Authority for

Northeast Iceland, the Soil Conservation Service, the National Energy Authority, the Environment

Agency of Iceland, the Icelandic Met Office and the Icelandic Road Association. The Icelandic National

Planning Agency received seven comments/opinions during the review period and sent these to the

Developer.

Landsnet sent the assessment report on high voltage transmission lines (220 kV) from Þeistareykir to

Bakki by Húsavík and an underground cable (132 kV) from Bjarnarflag to Krafla, Norðurþing

Skútustaðahreppur Municipality and Þingeyjarsveit Municipality to the Icelandic National Planning

Agency and requested the Agency's opinion on the EIA on construction. The construction of high

voltage transmission lines is connected with proposed energy generation in the Krafla and Þeistareykir

area and the construction of the aluminium plant at Bakki. The Minister for the Environment and

Natural Resources ruled that the environmental effects of all these projects should be assessed during

the same period, in a joint assessment. The scope of the project meant that the Icelandic National


4

Planning Agency needed more than the usual four week time limit to issue an opinion (until the 25th

of November, 2010). The process included a visit to the proposed project site.

1.2 DOCUMENTS SUBMITTED FOR THE OPINION OF THE ICELANDIC NATIONAL PLANNING AGENCY

Initial Environmental Impact Statement: High voltage transmission lines (220 kV) from Krafla and

Þeistareykir to Bakki by Húsavík. Underground cable (132 kV) from Bjarnarflag to Krafla.

Skútustaðahreppur Municipality, Þingeyjarsveit Municipality and Norðurþing. April, 2010.

Other documents: The following expert reports were submitted as supporting documents:

Appendix 1: Visual impact

Ásýnd/Landslag- Aðferðafræði- Ragnar Heiðar Þrastarson, Mannvit, 2009.

Appendix 2: Energy generation

Orkuflutnings mannvirki frá Kröflu og Þeistareykjum til Húsavíkur -Jarðfræði, efnistökusvæði og

verndargildi jarðmyndana. Eiríkur Freyr Einarsson. Mannvit, 2008.

Appendix 3: Vegetation in geothermal areas

Gróðurfar á háhitasvæðum og fyrirhugðum línu- og vegstæðum á Norðausturlandi. Guðmundur

Guðjónsson, Kristbjörn Egilsson og Rannveig Thoroddsen. Unnið fyrir Landsvirkjun, Landsnet hf. og

Þeistareyki ehf. sumarið 2007.Náttúrufræðistofnun Íslands, okt. 2008 (NÍ-08009).

Appendix 4: Birdlife in the construction area

Fuglalíf á framkvæmdasvæðum fyrirhugaðra háhitavirkjana í Þingeyjarsýslum. Þorkell Lindberg

Þórarinsson og Aðalsteinn Örn Snæþórsson. Unnið fyrir Landsvirkjun, Landsnet hf. og Þeistareyki ehf.

sumarið 2007. Náttúrustofa Norðausturlands, desember 2007.

Appendix 5: Effects on tourism and outdoor recreation

Áhrif fyrirhugaðrar virkjunar á Þeistareykjum og háspennulína frá Kröflu að Bakka við Húsavík á

ferðaþjónustu og útivist. Dr. Edward H. Huijbens. Unnið fyrir Landsvirkjun, Landsnet hf. og Þeistareyki

ehf. 2007-2008. Ferðamálasetur Íslands, janúar 2008.

Appendix 6: Detailed survey

Deiliskráning vegna fyrirhugaðra framkvæmda við línustæði og orkuvinnslustöðva, Krafla-Gjástykki-

Þeystareikir-Bakki. Uggi Ævarsson. Unnið fyrir Landsvirkjun, Landsnet hf. og Þeistareyki ehf. sumarið

2007. Fornleifastofnun Íslands SES, 2007 (FS-366-07211).

Appendix 7: Þeistareykir Road/ Kísilvegur Road

Þeistareykjavegur. Þeistareykir – Kísilvegur. Vegagerð ríkisins, desember 2008.


5

The following opinions were received:

• Norðurþing, with a letter dated the 4th of June 2010.

• Skútustaðahreppur Municipality, with a letter dated the 12th of July 2010.

• Þingeyjarsveit Municipality, with a letter dated the 24th of June 2010.

• Iceland Fire Authority, with a letter dated the 12th of May 2010.

• The Archaeological Heritage Agency of Iceland, with a letter dated the 4th of June 2010.

• The Public Health Authority in Northeast Iceland, with a letter dated the 1st of June 2010.

• The Soil Conservation Agency, with a letter dated the 10th of June 2010.

• The National Energy Authority, with a letter dated the 9th of June 2010.

• Tjörneshreppur, with a letter dated the 12th of June 2010.

• The Environment Agency of Iceland, with a letter dated the 29th of June 2010.

• Icelandic Meteorological Office, with a letter dated the 28th of June 2010.

• The Icelandic Road Association, with a letter dated the 4th of June 2010.

The Icelandic Tourist Board did not respond.

Following comments were received:

• Birkir Fanndal Haraldsson, with a letter dated the 12th of June 2010.

• Dagur Jóhannesson and Arnþrúður Dagsdóttir, with a letter dated the 13th of June 2010.

• Indriði Úlfsson, in an email dated the 14th of June 2010.

• Jón Illugason, in an email dated the 14th of June 2010.

• Jónas Jónasson and Rósa Kjartansdóttir, in an email dated the 13th of June 2010.

• The Icelandic Environment Association, in an email dated the 14th of June 2010.

• Iceland Nature Conservation Association, with a letter dated the 14th of June 2010.

• Ragnar Þór Árnason, on behalf of the residents and owners of land in Einarsstaðir, Skarð and

Skarðaborg in Reykjahverfi, with a letter dated the 11th of June 2010.

The comments from the Iceland Nature Conservation Association were responded to in a joint

assessment for the aluminium plant at Bakki, Þeistareykir Geothermal Power Station, Krafla

Geothermal Power Station II and the high voltage transmission line from Krafla and Þeistareykir to

Bakki.

Assessment report: High voltage transmission lines (220 kV) from Krafla and Þeistareykir to Bakki by

Húsavík. Underground cable (132 kV) from Bjarnarflag to Krafla. Skútustaðahreppur, Þingeyjarsveit

and Norðurþing Municipalities. October, 2010.


6

Other documents: The assessment report was accompanied by the same expert reports referred to in

the IEIS as well as appendix 8: Comments and opinions during the review period of the IEIS.

2 IMPLEMENTATION AND OBJECTIVES The assessment report states that Landsnet plans to construct two 220 kV high voltage transmission

lines, approximately 120 km in length, with the aim of transmitting electricity from power stations in

high temperature areas in Krafla and Þeistareykir to Bakki by Húsavík. A 10km underground cable

(132 kV) will also be laid from the power station in Bjarnarflag to the Krafla Geothermal Power Station.

The high voltage transmission lines will be constructed in five phases: Krafla Lines 4 and 5,

Hólasandur Lines 1 and 2 and Þeistareykir Line 1. All phases will be able to transmit 500 MVA and

Hólasandur Line 1 and Þeistareykir Line 1 will be able to transmit approx. 950 MVA. Galvanised

steel frame transmission towers with a concrete base (M-type, 14-30 m in height but mostly 22-23 m)

will be used as supporting transmission towers for the high voltage transmission lines. Corner

transmission towers will mostly be steel frame columns. Guy wires from transmission towers will be

connected to the ground using anchors (anchoring plates or anchoring bolts).

Krafla Line 1 will run alongside Krafla Lines 4 and 5, from the substation at the Krafla Geothermal Power

Station in (across the southern part of the Leirhnjúkshraun Lava Field), westward to Hrafnabjörg and

the substation in Hólasandur. Hólasandur Lines 1 and 2 take over at this point and run in separate

directions. Hólasandur Line 1 will run to the west of the Lambafjöll Mountains and northward, past

Geldingadal and Höskuldsvatn Lake, whereas Hólasandur Line 2 will run northward from the

substation, up to the Kvíhólafjöll Mountains and past the Bæjarfjall Mountain up to the substation by

Þeistareykir. Þeistareykir Line 1 will run from the substation at Þeistareykir and across

Jónsnípuskarð Pass up to Höskuldsvatn Lake. Þeistareykir Line 1 will meet Hólasandur Line 1 to the

west of Höskuldsvatn Lake and the lines will run alongside each other northward between the

Krubbsfjall Mountain and Gyðuhnjúkur and up to the substation at the proposed industrial site at

Bakki by Húsavík.

Table 1: Key indices of individual lines (table 2.2 page 16 in the assessment report).

KR4 KR5 HS1 HS2 TR1 Total

Length, km 14 14 44 19 29 120

Estimated

number of

transmission

towers

48 48 134 57 88 375

Average

spanlength,

m

294 292 331 332 331 320

Average

height

transmission

towers

22 22 23 23 23 23


7

The underground cable will be laid from Bjarnarflag Geothermal Power Station and up to þjóðvegur 1

(National Road 1) and alongside the road across Námaskarð. The cable will run alongside a water

pipeline from Námaskarð and up to the access road to Krafla Geothermal Power Station. The cable will

then follow the road up to the Krafla Geothermal Power Station substation. The cable will be laid in a

canal which will be 1 m in depth and 1.5 m in width. The cable is expected to transmit at least 110

MVA. The substation for high voltage transmission lines will be in Bjarnarflag, by Krafla and in

Hólasandur, Þeistareykir and Bakki. The trails alongside the lines will be 4 m in width and 10-50 cm in

height. The trails will mostly be new and will cover a distance of 95 km. Older trails in need of

reinforcement will also be used but new rails will be created from the old trails and up to the

transmission tower bases. The final location of trails will be decided during the construction period.

The estimated total quantity of filling materials for trails, construction pads, foundations and anchors

will be 250,000 m3, of which 20,000 m3 will be used for construction pads. Materials will be extracted

from 27 material extraction areas, controlled by the Icelandic Road Association, Landsnet, Landsvirkjun

and Þeistareykir ehf. New extraction sites (mines) will also be needed.

The purpose of the high voltage transmission line project is to ensure the supply of electricity to

industrial sites at Bakki by Húsavík from high temperature areas in Þingeyjarsýsla District, as well

as facilitating increased general electricity usage within the area. The purpose of underground cables

between Krafla Lines 4 and 5 (KR4 and 5), Hólasandur Line 1 and 2 (HS1 and 2), Þeistareykir Line 1 (TR1)

Bjarnarflag Geothermal Power Station and Krafla Geothermal Power Station is to connect

Bjarnarflag Geothermal Power Station with Landsnet‘s transmission network.

The IEIS shows that Dagur Jóhannesson and Arnþrúður Dagsdóttir repeatedly objected to plans to raise

high voltage transmission lines across the Jónsnípuskarð Pass. They voiced this opinion both in

connection with the Regional Plan for high temperature areas in Þingeyjarsýsla District and in

connection with the advertised draft of the assessment plans for the high voltage transmission line

from Krafla across Þeistareykir and up to Bakki. They recommended that the high voltage transmission

line from Þeistareykir should be laid alongside the proposed road for Þeistareykir Geothermal Power

Station and between Höfuðreiðarmúla and Sæluhúsmúla (Option A1c in the EIA for the Regional

Plan) instead of across Jónsnípuskarð Pass (Option A1d). The line across Jónsnípuskarð Pass would

cause significant disturbance to land and would have a significant visual impact. Jónsnípuskarð Pass is

also located in an area known for volatile weather conditions and icing, whereas the line to the north

of Höfuðreiðarmúla would be better sheltered. The cooperative committee for the Regional Plan has

pointed out that the assessment on the visual impact of the proposed options was in fact part of the

EIA of the plan and the line across Jónsnípuskarð Pass would be 1.3 km shorter than a line to the north

of Höfuðreiðarmúla.


8

The opinion given by Dagur Jóhannesson and Arnþrúður Dagsdóttir on the draft for assessment plans

also pointed out that the criteria developed for the EIA of the Regional Plan was unsatisfactory and the

high voltage transmission line between Höfuðreiðarmúla and Sæluhúsmúla should not have been

rejected. The EIA on construction could be utilised to discuss and assess the positive aspects of each

option i.e. a high voltage transmission line across Jónsnípuskarð Pass and between Höfuðreiðarmúla

and Sæluhúsmúla. Landsnet responded that the Regional Plan had discussed different transmission

line routes the visual impact was assessed and discussed in the IEIS. Finally, Dagur and Arnþrúður

point out the fact that the IEIS only assessed the visual impact of the line across Jónsnípuskarð Pass

and that a comparison of the proposed options had not been completed. High voltage transmission

lines across Jónsnípuskarð Pass would affect a 7 km stretch of untouched land and the roads and

transmission towers would be obvious to the naked high in mountain ridge areas. This type of

disturbance would not be justified by the fact that the proposed high voltage transmission lines would

be 1.3 km shorter. The construction of the line alongside the proposed power station road could

however decrease the negative environmental effects of the project.

Landsnet´s response reaffirms the results of the EIA of the Regional Plan for high temperature areas

which states that both transmission routes: Route A1d across Jónsnípuskarð Pass and A1c to the north

of Höfuðreiðarmúla, will both traverse the Þeistareykir Lava Field. The route across Jónsnípuskarð

Pass runs along the Þeistareykir Lava Field to the west from Guðfinnugjá and traverses less disturbed

land than the route across Höfuðreiðarmúla. The transmission route for Höfuðreiðarmúla conforms

to the policy outlined in the plan which states that roads and lines should run alongside each other

wherever possible but there is another line already located in the area (Kópasker Line) and there would

be negative, combined effects if another line were to be added to the area. The route across

Jónsnípuskarð Pass better reflects the policy set out by Norðurþing that high voltage transmission lines

should run to the west of Höskuldsvatn Lake and to Bakki by Húsavík. Option A1d was chosen as a

result of this. This would enforce Norðurþing‘s policy and the environmental criteria set out in the

Regional Plan: The lines would partly run alongside the proposed road from Húsavík to Þeistareykir

and then across the lava in a smaller area than the route outlined in the Höfuðreiðarmúla option (A1c).

Landsnet‘s response points out that the cooperative committee for the Regional Plan did not agree

with the rationale presented by Dagur and Arnþrúður and there had been no indication that the

transmission route could change as a result of visual impact. The relative parties within the

municipalities will therefore include the Jónsnípuskarð Pass route in their general/master plan. The

IEIS only included the options that had already been approved in the Regional Plan and their visual

impact assessed. The report did not compare all possible options at the Regional Plan stage. Landsnet

supplied photographs and computer-generated images which show that the proposed transmission


9

towers and trails across Jónsnípuskarð Pass would merge neatly with the landscape and would not be

obvious from busy areas. Landsnet concludes that high voltage transmission lines across

Jónsnípuskarð Pass would not have a significant visual impact. Landsnet also points out the fact that

the proposed high voltage transmission lines across Jónsnípuskarð Pass will cross the Kópasker Line

(by Árnahvammur) which would mean that specialised transmission towers would not be required.

However, these transmission towers would be required if the line were to pass through rather narrow

land by Höfuðreiðarmúla. The lines from Þeistareykir would cross the Kópasker Line and turn sharply

westward, running alongside the Kópasker Line (the lines would vary in height). This would create a

strange mix of mismatched tower types which could potentially have a significant visual impact. There

would also be a significant combined negative effect of the line and the proposed road to Þeistareykir.

These issues were considered when the municipalities approved the Regional Plan for high

temperature areas, with a transmission line across the Jónsnípuskarð Pass. The route across

Jónsnípuskarð Pass is also 1.3 km shorter and would cause fewer disturbances to the lava than the

Höfuðreiðarmúla route. Landsnet believes that there is no significant difference between the

Jónsnípuskarð Pass and Höfuðreiðarmúla option with regard to the security of supply, when icing

issues are considered.

The Icelandic National Planning Agency points out that the Minister for the Environment and Natural

Resources approved the Regional plan for high temperature areas in Þingeyjarsýslu 2007 - 2025

in January of 2008. The procedure for the Regional Plan was in accordance with the Planning and

Building Act No. 73/1997 and the Environmental Assessment of Plans and Programmes Act No.

105/2006. The Regional Plan outlines a clear policy on the utilisation of high temperature areas in

Krafla, Bjarnarflag, Þeistareykir and in Gjástykki as well as the policy on the construction of high voltage

transmission line, power station roads and the demarcation of protected areas by energy generation

areas. The scope of the EIA reflected its accuracy and the role of the Regional Plan. Specific research

was not undertaken as baseline data on environmental aspects that could be potentially affected was

utilised. The construction project policies outlined in the Regional Plan would eventually be subject

to Act No. 106/2000 on environmental effects and the process, which would be based on more exact

data, could lead to a result that would require changes to the policy outlined in the Regional Plan. This

type of change would require the approval of the municipalities involved in the development of the

Regional Plan but there is generally nothing to prevent more extensive data leading to changes in the

policies outlined for regional planning.

Security of supply must be ensured as far as possible in the proposed construction of high voltage

transmission lines from Krafla across Þeistareykir and up to Bakki. Potential environmental effects

must also be minimised and the Icelandic National Planning Agency believes that in cases where both


10

options fulfil security concerns, then the regulations on the environmental impact of construction

should be considered and the option with the least environmental impact should be chosen. The

Icelandic National Planning Agency has concluded that the Environmental Impact Assessment (EIA)

shows that the route chosen for the high voltage transmission line across Jónsnípuskarð Pass will have

a significant and irreversible negative impact on the Þeistareykir Lava Field (see chapters 3.2 and 3.3).

Landsnet proposed two options for Þeistareykir Line 1 as a result of the Regional Plan (across

Jónsnípuskarð Pass or to the north of Höfuðreiðarmúla). Both options involved lines passing through

the Þeistareykir Lava Field. The Icelandic National Planning Agency believes that both options would

have a similar effect on the lava and that there are no well-known mitigation measures to reduce the

impact. The Höfuðreiðarmúla option is considered to be the most feasible with regard to security of

supply and the Icelandic National Planning Agency believes that Landsnet should assess the possibility

of developing another option for the route for Þeistareykir Line 1 (where the line would pass

Höfuðreiðarmúla).

2.1 CONNECTED CONSTRUCTION

The assessment outlines plans for the construction of a 16 km road from Bæjarfjall Mountain and up

to the Kísilvegur Road in Hólasandur, which is a continuance of the proposed Þeistareykir Road,

between Húsavík and Þeistareykir. The road will be 7 m in width and raised to a height of 50-70 cm

with a load bearing road base and an estimated speed limit of 80-90 km/hr. The distance between

Hólasandur Line 2 and the road will be at least 100 m and trails will connect the road and the line. The

road will follow the current road trail over an 8 km stretch, alongside Bæjarfjall Mountain and south

of Kvíhólafjall Mountain but the road will then follow a new road path in Neðra- Bóndhólshraun and

up to the Kísilvegur Road. Two routes can be considered at this point; each one covering approx. 5 km

(routes A and B). The estimated material needs are 340,000 m3 (route B) to 360,000 m3 (route A). The

materials will mostly be sourced from mines within the area and material from road cut will be approx.

81,000 m3 (route A) to 135,000 m3 (route B).

The proposed road will be within the proposed construction area for transmission line trails and the

high voltage transmission lines. The road will therefore not have a significant impact on the landscape

beyond those caused by the proposed construction work in connection with the high voltage

transmission lines. The road will not disturb rare vegetation communities but will have a considerable,

localised negative impact on vegetation. The assessment shows that the proposed road could have a

negative impact on nesting areas and that construction work and traffic could disturb birdlife. The road

will generally have a negligible effect on birdlife but access to Ptarmigan hunting areas could increase

as a result of the road which could have an indirect but somewhat negative impact on the survival of

the falcon. Furthermore, two cairns and one road will also be affected by the construction of the road.


11

Supervisory bodies will be given the task of enforcing any regulations with regard to work carried out

in the vicinity of these remains. If the protection of archaeological remains should fail, then the

Archaeological Heritage Agency of Iceland will be consulted on the removal of the remains. The

Developer believes that the potential environmental effects of the road from Bæjarfjall Mountain and

up to the Kísilvegur Road are acceptable.

The Environment Agency of Iceland believes that the road construction from Bæjarfjall Mountain and

up to the Kísilvegur Road is part of the construction project for the high voltage transmission line, as

the IEIS did not outline any plans for the location of access roads and transmission line bases for

Hólasandur Line 2 and Þeistareykir Line 1 and a trail that would be consistent with these plans. The

Environment Agency of Iceland also points out that additional materials will be required for the

construction of a road and construction pads from Bæjarfjall Mountain and up to the Kísilvegur Road

and that the estimated quantity required could be anything up to 610,000 m3 for both construction

projects, of which approx. 80,000 m3 will come from road cut. (route A).

Landsnet reiterates that proposed construction work on Hólasandur Line 2 means that the

construction of a road would be unnecessary. Road construction is not a part of the construction

project on the high voltage transmission line and material extraction plans would therefore not be

required. The route of the proposed road is used to demarcate trails to minimise any later disturbance

as a result of road construction that may or may not be carried out at a later stage.

The Soil Conservation Service of Iceland points out that the IEIS shows that vegetation will disappear

underneath the proposed road and will be disturbed as a result of soil disturbance during road

construction. Plans for re-vegetation (or equivalent measures) as a result of land lost during

construction must be outlined.

Landsnet‘s response outlines the fact that the land is poorly vegetated and that the high voltage

transmission lines and the proposed road will run alongside each other within the area. Sowing

measures will not be implemented in unvegetated areas. Other finishing work will be completed in

accordance with the description in Chapter 3.5.

The Archaeological Heritage Agency of Iceland comments on the IEIS include the suggestion that any

archaeological remains within the road construction site would need to be identified. The results of

this assessment would then be presented to the Agency and would be subject to conditions set out by

the Archaeological Heritage Agency of Iceland, on mitigation measures.


12

Landsnet assumes that an assessment of archaeological remains will be conducted in the area not

included in the archaeological survey in connection with high voltage transmission lines before

construction work on the road begins.

The Icelandic National Planning Agency believes that the proposed road across Hólasandur to

Þeistareykir is connected with the construction project on high voltage transmission lines with a view

to any cumulative effects on the environment. The Icelandic National Planning Agency points out

that the current road across Hólasandur and up to Þeistareykir will only be partly utilised during the

construction phase of the transmission line project and to provide access points for maintenance work

in the future i.e. the section to the south of Þeistareykir and up to the point where the road meets the

turn-off point which is located to the east of the Gæsafjöll Mountains (coordinate 40.000 in Figure 3.3

in the assessment report). The current road is located far away from the proposed line route from

this point and up to the proposed substation for the high voltage transmission line in Hólasandur and

Landsnet plans to create new trails in this section of the road which will disturb untouched land. The

Icelandic National Planning Agency believes that these trails should follow the proposed road site for

the constructed road. This layout would prevent any additional environmental effects to those already

expected in this area as a result of road construction. The Icelandic National Planning Agency

reiterated the importance of this in the early stages of the process and Landsnet has subsequently

decided to utilise the proposed route of the constructed road to create the necessary trails. The actual

construction of the road at a later date would require and environmental assessment on the basis of

Item 10ii in appendix 1 of the law on Environmental Impact Assessments where relics must be

identified and reclaimed vegetated areas must replace areas disturbed by road construction.

2.2 OTHER OPTIONS

Landsnet identified a number of transmission routes for electricity within the area during the

preparation period for the development of the Regional Plan for high temperature areas in

Þingeyjarsýsla District. These were assessed alongside other structures connected to energy

generation within the area with a view to the overall effects of land usage on the environment.

Option 1: The results of the Regional Plan for transmission routes shows that the option put forward

by Landsnet was the option chosen (Option 1), i.e. alongside lines from Krafla and up to the proposed

substation in Hólasandur, from Höskuldsvatn Lake and up to Bakki and a simple line along two routes

from Hólasanduri: One across Þeistareykir and up to Höskuldsvatn Lake and the other west of

Lambafjöll Mountains and up to Höskuldsvatn Lake up to Bakki. The EIA for Option 1 are included in

the assessment report.


13

Option 2: In Option 2, high voltage transmission lines would run alongside each other from Krafla,

across Þeistareykir and up to Bakki. The area to the west of Bæjarfjall, by Þeistareykir, the Þeistareykir

Lava Field and Jónssnípuskarð could however create more technical problems and negative

environmental effects than a simple line running either side of Lambafjall (Option 1). The land in the

Bæjarfjall Mountain area and up to Þeistareykir is covered in fissures and there is therefore only a small

area of viable land for the construction of high voltage transmission lines. The vegetation in the area

is sensitive and the geological formations are unique. There are a number of archaeological remains

and protected land areas, according to the Regional Plan for high temperature areas in Þingeyjarsveit.

Two lines across Þeistareykir would therefore increase the visual impact, would have more of a

negative impact on the experience of tourists and would increase the negative effects on the unique

landscape, geological formations and vegetation within the area. Two lines from the proposed

substation at Hólasandur and across Þeistareykir, Jónsnípuskarð Pass and up to Höskuldsvatn Lake

would increase the likelihood of bird impact whereas a simple high voltage transmission line could

have a permanent and somewhat negative effect on birdlife. The trails that would accompany Option

2 would be 34 km shorter than in Option 1 and would therefore require less material.

Landsnet´s main option (Option 1) would better fulfil the objectives of the Regional Plan for high

temperature areas in Þingeyjarsýsla District, the policies of the relevant municipalities and security of

supply than Option 2.

Zero option: The zero option is not an option (the option not to construct a high voltage transmission

line to Bakki by Húsavík). A policy has been developed on the utilisation of geothermal energy for

energy generation in Þingeyjarsýsla District and high voltage transmission lines are an essential part of

transmitting electricity from the proposed geothermal power stations.

The Environment Agency of Iceland points out that Option 2 would constrict the Þeistareykir area

more than Option 1 and supports Landsnet‘s opinion that Option 2 would be likely to have a greater

negative environmental effect than Option 1.

The Icelandic National Planning Agency agrees with the Environment Agency of Iceland and Landsnet

and believes that the doubling of the number of lines across the Þeistareykir area (Option 2) would

have a greater negative environmental effect than Landsnet‘s Option 1.


14

3 RESULTS OF THE ENVIRONMENTAL IMPACT ASSESSMENT (EIA)

3.1 CHARACTERISTICS AND EXTENT OF ENVIRONMENTAL EFFECTS

The Environment Agency of Iceland points out that the Developer‘s definitions with regard to terms

and explanations as to the extent of effects do not conform with the instructions given by the Icelandic

National Planning Agency in December 2005 on the characteristics and extent of environmental

effects.

The Developer responded by pointing out that the report‘s author had used the term ‘somewhat’ in

the Environmental Impact Assessment on the construction project. The justification for this decision

was the author‘s opinion that the difference between the term negligible and significant was too great

and the term ‘somewhat’ was therefore added to the scale. The decision was made in cooperation

with the Icelandic National Planning Agency at that time as a result of the IEIS from Alcoa Fjarðaál. The

methodology outlined by the Agency in their instructions can therefore be deviated from, in

cooperation with the Icelandic National Planning Agency.

The Icelandic National Planning Agency points out that the Developer‘s assessment report included an

assessment of the effect of construction on specific environmental aspects. The extent of these effects

is described by using ‘extent grades’, where the most negative grade is significantly negative, followed

by considerably negative, somewhat negative and negligible/no effects. The scale also includes

positive effects graded as somewhat positive, considerably positive and finally significantly positive.

The instructions from the Icelandic National Planning Agency (since 2005) on the categorisation of

environmental aspects, the criteria for characteristics and the extent of environmental effects include

proposals for terms on the extent of the effects which support the Environmental Impact Assessment

(EIA). The Icelandic National Planning Agency is currently reviewing these instructions and the Agency

believes that many cases require a description of the extent of the effects using a grade which the

Agency calls ‘somewhat negative’, which represents the stage between considerably negative and

negligible effects and is similar to the Developer‘s definitions in the assessment report. However, this

would mostly be used to describe localised effects which would not cover large areas. The area would

not be protected and would not be in any way sensitive to change but the effects could be permanent

and irreversible. The Icelandic National Planning Agency therefore chooses to use the same terms as

those used by the Developer in the assessment report to describe the combined environmental effects

of the four construction projects.


15

3.2 VISUAL IMPACT AND EFFECTS ON LANDSCAPE, PROTECTION, OUTDOOR RECREATION AND

TOURISM

Landscape and visual impact: The assessment report shows that the landscape within the

construction area was assessed and categorised into landscape units on the basis of geology,

vegetation, hydrological conditions, land usage and land form. The value of the land was assessed

according to its status: Untouched wilderness, outdoor recreation, protected as a result of the direct

potential effect on the characteristics and appearance of the land and geothermal activity at the

surface. Altimetry data has been utilised to assess where and when high voltage transmission lines

and their connecting trails will become conspicuous in the landscape. The basis for this is the idea

that transmission towers are generally not visible at a distance of more than 5 km. The assessment

report also shows that the proposed high voltage transmission lines will run across diverse landscapes.

The landscape by Þeistareykir is considered special as a result of the diverse geothermal formations,

solfataras, fumaroles and geothermal plant life. The Þeistareykir area is on the Nature Conservation

Register and is partly protected by the Regional plan for high temperature areas in Þingeyjarsýsla

District 2007-2025. Craters present within the landscape units of Þeistareykjabungu are on the Nature

Conservation Register and the area is part of an untouched wilderness. The value of Þeistareykir and

Þeistareykjabunga is therefore high and is followed by landscape units (from south to north) in

Nónbugur, Leirhnjúkshraun, Hlíðarfjall, Bóndhólshraun, Gæsafjall Mountains, Draugagrundir,

Lambafjall Mountains, Botnsvatn and Grísatungufjöll. Landscape units between Bæjarfjall and

Lambafjall have a rather low value (the second lowest value category) and this includes Hólasandur,

Kvíhóla, Bæjarfjall, Austurhlíð Lambafjöll, Þeistareykir Lava Field and Skildinga and Stóravítishraun

Lava Field. The landscape units to the west and north of the Lambafjöll Mountains generally have a

low value; from Kasthvamsheiði in the south to the Bakki River in the north, with the exception of the

Höskuldsvatn Lake, Höskuldsvatnshnúkur, Botnsvatn and Bakki, which are all in the second lowest

value category.

The assessment report shows that the high voltage transmission line will have a somewhat negative

overall effect on the landscape. The proposed construction of a high voltage transmission line across

Þeistareykir will alter the physical appearance of the area and will have a significant negative effect

on the physical landscape. High voltage transmission lines will be located in the middle of the

Þeistareykir Lava Field and will have a considerable negative effect on the lava, which is unique as a

result of its texture and appearance which is an obvious characteristic of the landscape. The area also

has special geological formations (lava channels and craters). The lines will also have a considerable

negative effect on the landscape in the Bóndhólshraun Lava Field, the eastern slope of Lambafjall


16

Mountain and by the Höskuldsvatn Lake and Höskuldshnjúka. Construction will also mean that the

aforementioned landscape units will no longer be considered an untouched wilderness. High voltage

transmission lines across the Leirhnjúkshraun Lava Field will affect the view from rambling paths in the

lava field and will have a considerably negative impact on the landscape. The proposed high voltage

transmission lines will run across five landscape units to the west of Lambafjall and will have a

somewhat negative impact on Bæjarfjall, where the high voltage transmission line across Hólasandur,

Þeistareykir, Þeistareykir Lava Field and Jónsnípuskarð Pass will be visible. The transmission towers

will also be visible in Krubbsfjall towards the direction of the coastline where the lines run across the

landscape unit in the Bakki River and Bakki. The proposed lines will also be conspicuous in

Hólasandur and the surrounding area and the impact on the landscape will be somewhat negative.

High voltage transmission lines are already located in landscape units in Grísatunga and Þríhyrninga

and the effects of the proposed construction work will therefore be less than expected i.e. somewhat

negative. The assessment report shows that mitigation measures have not been planned in connection

with the effects on the physical landscape.

The Environment Agency of Iceland believes that the aspects used to assess the value of landscape

units (untouched wilderness, outdoor recreation, geothermal activity at the surface and special

protection) do not give an accurate picture of the value of the units. Geological formations could for

instance have a conservation value, despite the fact that they are not considered candidates for special

protection, according to the law. The Agency points out that the landscape unit in Hlíðarfjall is

considered to be an untouched wilderness and the Agency believes that its value is greater than the

IEIS indicated. The Agency believes that the landscape units in Leirhnjúkshraun and Hlíðarfjall will be

significantly and negatively affected by the proposed construction.

Landsnet points out that the use of plans and regulations is based on the policies outlined by the state

and by the relevant municipalities with regard to protection. The visual impact of high voltage

transmission lines will be significantly negative in areas within 1 km of the transmission lines but

Landsnet does not agree with the opinion that the overall visual impact within the landscape units in

Hlíðarfjall and Leirhnjúkshraun will be significant. However, tourists will probably venture away from

the rambling paths across Leirhnjúkshraun and in the area surrounding Hlíðarfjall and head towards

higher land in the mountain area. Landsnet can therefore agree with the Environment Agency of

Iceland on the value of Hlíðarfjall and the assessment report has increased the value of the area (which

now has a rather high value) and the effects of the high voltage transmission line on this landscape

unit is now categorised as somewhat negative.


17

The assessment report shows that the high voltage transmission line will naturally have a considerable,

negative visual impact at a distance of anything up to 1-2 km and would still be considered somewhat

negative at a distance of 2-5 km from the transmission towers. The proposed structure will be

conspicuous by Þeistareykir and the visual impact will therefore be significantly negative. High voltage

transmission lines will be conspicuous by Bakki, from the Húsavíkurfjall Mountain, southeast of

Botnsvatn, west of Höskuldsvatn Lake, by Þeistareykir, at viewing locations in Leirhnjúkshraun and

from the Krafla area (Krafla already has a number of high voltage transmission lines and other

structures). The high voltage transmission lines will be obvious on the national road from Kísilvegur

Road by Hólasandur, by Þeistareykir and by Bakki. The high voltage transmission lines will generally

not be easily seen from residential areas and will not be seen in Húsavík or on the national road up to

the farm (to the south) or from outdoor recreation areas by Botnsvatn, the residential area by

Reykjahlíð or the national road surrounding it. High voltage lines will blend into the landscape and

will therefore be less visible from Húsavíkurfjall and the Krubbsfjall Mountains, to the west of

Höskuldsvatn Lake, from Hlíðarfjall Mountain and Reykjahlíðarheiði therefore lessening the visual

impact. Four material extraction areas will be easily seen from busy areas and material extraction in

these areas will have a somewhat negative visual impact. The assessment report shows that mitigation

measures have not been planned in connection with the visual impact of high voltage transmission

lines.

Residents and owners of the Skarðaborg, Skarð and Einarsstaðir í Reykjahverfi Farms commented

on plans to construct a high voltage transmission line across Jónsnípu and down to Árnahvammur.

They recommended that the line should be constructed to the north of Höfuðreiðarmúla and then

westward towards the south banks of Höskuldsvatn Lake and alongside the proposed road route

outlined in the general/master plan for the town of Húsavík. This would reduce the visual impact and

would not spoil the physical appearance of land from Árnahvammur and up to Höskuldsvatn Lake.

Landsnet agrees that the physical appearance of the area by Árnahvammur would be altered as a result

of the transmission line (Þeistareykir Line 1) and the line would be more visible in this area than in the

area north of Höfuðreiðarmúla. The visual impact in Árnahvammur will however be less than the

combined visual impact of lines and roads by Höfuðreiðarmúla (see Landsnet‘s response to

comments made by Dagur and Arnþrúður above).

Residents and owners of the Skarðaborg, Skarð and Einarsstaðir í Reykjahverfi Farms commented

that high voltage transmission lines to the west of Lambafjall (Hólasandur Line 1) will be located to

the west of the Kópasker Line and would penetrate sensitive vegetated areas, cultivated over a long

period of time. The line will also be visible from farms close by. Recommendations include the proposal


18

that the lines could run alongside each other where the Hólasandur Line meets the Kópasker Line and

up to the north end of Höfuðreiðarmúla. The Hólasandur Line would then run westward, past the south

banks of Höskuldsvatn and alongside the proposed road route outlined in the general/master plan for

the town of Húsavík.

Landsnet‘s response explained that efforts to minimise any operational disturbances include the

avoidance of areas that are susceptible to icing. Landsnet points out that the Kópasker Line passes

through the highland area in Höfuðreiðar and is susceptible to winds from the northwest and

experience of the line shows that icing can be expected in this area. Landsnet therefore believes that

this option would not ensure the satisfactory security of supply. The route is also 3 km longer than the

proposed line route. The route chosen by Landsnet will lead to more disturbances in vegetated areas.

Landsnet will attempt to minimise this disturbance by creating side trails to the transmission towers

which are able to carry heavy machinery and land reclamation measures will be implemented in

cooperation with the Soil Conservation Service. Landsnet also points out that the distance from the

farms to the lines would be 3.5-4 km. The lines would be more obvious if they were further away and

higher up.

The district council of Tjörneshreppur has voiced its concerns with regard to the negative visual impact

of high voltage lines on tourism and outdoor recreation in the area next to Bakki. The residents of

Héðinshöfða 2 have spoken against the location of the substation by Bakki and believe that it will be

too conspicuous and easily seen from the farm; that the high voltage transmission lines will be

conspicuous and will depreciate the value of the farm. Residents in Héðinshöfða 1 have pointed out

the fact that their initial concerns regarding the visual impact of high voltage transmission lines and

their demands for an underground cable have not been addressed.

Landsnet‘s response outlines the fact that the visual impact of the high voltage transmission line will

be significant up to a distance of 2 km from the lines but will decrease as the distance increases. The

effects will be considerably negative in the area where the lines meet the aluminium plant at Bakki.

High voltage transmission lines will have considerable negative impact on tourists who enjoy the

natural surroundings by Bakki, but will not hinder access to the Bakki area. The lines will be a part of

a number of structures in the area next to Bakki and these structures will be visible. The lines will

blend in with the landscape in Héðinshöfða which will reduce the impact. Landsnet also points out the

fact that overhead lines obviously have a greater visual impact but underground cables cause more

environmental effects and overhead lines are easier to dismantle and remove.

Conservation value: The assessment report shows that the largest part of the proposed high voltage

transmission line will be located within the water catchment area in Mývatn and Laxá which are both


19

protected under regulation No. 97/2004. The high voltage transmission lines will end close to

Bakkifjöru and Bakkihöfða and the affected area of the lines will penetrate Þeistareykir. All these areas

are included in the Nature Conservation Register. The lines will also run through an area which is

locally protected according to the Regional plan for high temperature areas in Þingeyjarsýsla District

2007-2025, by Þeistareykir and in the Þeistareykir Lava Field. Krafla Lines 4 and 5 will run across a

locally protected area by Þríhyrning to the west of the Krafla geothermal Power Station and across

Leirhnjúkshraun Lava Field. The assessment report shows that the Environment Agency of Iceland had

proposed a protection order for Leirhnjúkshraun and construction will not be approved in the area

until the results of the proposal have been released.

Landsnet believes that protected areas will be disturbed as a result of the construction of high voltage

transmission lines and the project will have a somewhat negative and to some degree permanent

effect on protected areas in Þeistareykir, in the Þeistareykir Lava Field and by Þríhyrning to the

west of the Krafla Geothermal Power Station. The effects will be negligible with regard to hydrological

conditions in Mývatn and Laxá and in the Bakkihöfða area.

The National Energy Authority points out that high voltage transmission lines will traverse protected

areas and electricity lines and underground cables disturb geological formations in these areas. The

irreversible environmental effects of these projects must be considered.

Landsnet‘s response confirms the fact that the proposed high voltage transmission lines will inevitably

have a somewhat negative and to some degree permanent effect on protected areas. The local

protection measures outlined in the regional plan for high temperature areas in Þingeyjarsýsla allow

for a belt of manmade structures that traverse the Þeistareykir Lava Field (area HÞ2) and in areas

where fissures and faults are located (area HÞ4).

Outdoor recreation and tourism: The proposed high voltage transmission lines are close to the main

rambling paths: Between Reykjahlíð and Leirhnjúkar, from North Hólasandur to Þeistareykir, from

Þeistareykir to Höfuðreiðarmúla, up to Húsavíkurfjall and alongside the coastline from Húsavík to

Bakki. Popular riding trails can also be found to the south of Gæsafjöll, across Hólasandur and

Þeistareykir and across the gorge between Höfuðreiðarmúla and Sæluhúsmúla. Telemark skiers

mostly travel across Reykjaheiði and Hólasandur and there are plans to develop a skiing area for

residents in Húsavík in the southern part of the Húsavíkurfjall Mountain. Rescue teams and jeep and

snowmobile enthusiasts mostly travel across Hólasandur and up to Jónsnípuskarð Pass and the areas

surrounding Þeistareykjabungu and Gæsafjöll. There is also an important Ptarmigan hunting area to

the east of Höfuðreiðarmúla, by Sæluhúsmúla and by Rauðhól, in the Lambafjöll Mountains, by

Þeistareykir and Bæjarfjall and also Gæsafjöll. Outdoor enthusiast cabins by Sæluhúsmúla and in


20

Þeistareykir. The results of research conducted by the Icelandic Tourism Research Center showed an

increase in tourists interested in the Þeistareykir area. There are popular outdoor recreation areas in

the vicinity of Bakki by Húsavík (Tjörnes, by Gónhól and in the Húsavíkurfjall Mountain).

The high voltage transmission lines will traverse rambling areas to the west of the Krafla Geothermal

Power Station and from Reykjahlíð to Gæsafjöll. The lines will run alongside routes used by outdoor

enthusiasts southward under the Kvíhólafjöll Mountains and northward alongside Bæjarfjall Mountain

and up to Þeistareykir. The lines in this area will be closer to the Ptarmigan hunting area by Bæjarfjall

and Þeistareykir. The high voltage transmission line from Þeistareykir and across Jónsnípuskarð

Pass will run alongside a riding trail across the Þeistareykir Lava Field and a rambling path from

Þeistareykir to Höfuðreiðarmúla and will also be in close proximity to the Ptarmigan hunting area to

the south of Jónsnípuskarð Pass. Plans have been put forward for a Telemark skier’s area by

Höskuldsvatn. High voltage transmission lines will be located in the area and will be easily seen from

the rambling path in Húsavíkurfjall. The lines will also traverse rambling and riding trails by Bakki.

The construction period for high voltage transmission lines will be accompanied by heavy vehicle traffic

on transmission line roads and line sites and noise. This will have a considerably negative impact on

tourism and outdoor recreation in the area. The effects during the operational period of the high

voltage transmission line will be considerably negative and permanent on outdoor enthusiasts seeking

out an untouched natural environment. The area will probably become less popular as a result.

Improved transport from Krafla and across Þeistareykir and up to Bakki (in connection with

construction work) will make the area more accessible and it could therefore be said that the high

voltage transmission line will have a considerably positive and permanent effect on outdoor

enthusiasts, who travel by vehicle. The effects of the high voltage transmission line on the experience

of skiers in the area to the west of Höskuldsvatn will be considerably negative, although the lines are

unlikely to have a negative effect on the development of the skiing area.

The Environment Agency of Iceland agrees that the proposed high voltage transmission lines will have

a considerably negative effect on nature tourism. The Agency points out that increased access to

outdoor recreation areas comes as a result of the grounds for construction and the development of

the area and not for outdoor enthusiasts or tourists. The Environment Agency of Iceland believes that

the effects of construction will be considerably negative as most of the visitors to the area are nature

tourists.

Landsnet‘s response agrees that the effect on tourists seeking out an untouched natural environment

will be considerably negative but will be negligible or somewhat positive for other tourists (e.g. those


21

travelling in vehicles). Landsnet believes that the value of nature tourism is no higher than that of any

other branch of tourism.

The Environment Agency of Iceland points out that the IEIS shows that tourism agents believe that

cooperation between the tourism industry, outdoor recreation enthusiasts and the Developer is

important to ongoing business within the area. Landsnet should put forward proposals on how

construction can be carried out in such a manner that it would decrease the impact on tourism and

outdoor recreation in the area and how the cooperation between the parties would be organised.

Landsnet points out that the proposed construction project was introduced to tourism agents in

connection with the release of the draft on proposals for assessment. Representatives from the

tourism industry have been involved in the development of the Regional plan for high temperature

areas in Þingeyjarsýsla District 2007-2025. Expectations of a positive impact from construction have

been identified according to this cooperation but there are also concerns about the negative impact

on tourism, as described in the IEIS. Mitigation measures have not been developed to reduce the

effects of construction on tourism and any future cooperation between Landsnet and tourism agencies

is expected to be successful.

The Icelandic National Planning Agency believes that the proposed construction will mainly have a

negative visual impact and a negative impact on the landscape. The Icelandic National Planning Agency

agrees with Landsnet that the proposed construction will have a significant negative effect on the

Þeistareykir area as the high voltage transmission lines and rails will traverse an area with a unique

natural environment and well vegetated land (when compared with neighbouring lava areas). The

Icelandic National Planning Agency believes that the effects will be irreversible in this area. The

Icelandic National Planning Agency also agrees with Landsnet that the high voltage transmission lines

will have a considerably negative effect on the eastern slopes of Lambafjall where the lines will traverse

outdoor recreation areas. There will also be a considerably negative impact from high voltage

transmission lines where they run across the Leirhnjúkshraun Lava Field, in an area already disturbed

by drilling. There will also be a considerably negative impact on Höskuldsvatn and Höskuldsvatnhnúka,

as the experience of the area as an untouched wilderness will be affected. The impact on the

untouched wilderness to the south of Hólasandur and to the west of Lambafjall, where the value of

the landscape is low (according to the report) will also be somewhat negative. The Icelandic National

Planning Agency agrees that overhead lines have more of a visual impact than underground cables.

However, the Icelandic National Planning Agency also believes that the laying of underground cables

can, under certain circumstances, have more of a negative impact on the landscape than overhead


22

lines and the extent of irreversible damage would also be more e.g. if high voltage transmission lines

are laid underground across lava areas.

The Icelandic National Planning Agency does not agree with Landsnet that the effects of the proposed

construction on the Þeistareykir Lava Field will be considerably negative. The assessment report shows

that Landsnet conducted an assessment of the landscape units, categorising and describing the

characteristics of the units, within the proposed construction area and also analysed the effects of the

proposed high voltage transmission line on the landscape and the potential visual impact. The value of

each landscape unit was assessed according to its status: Untouched wilderness, outdoor recreation,

protected and geothermal activity at the surface. The Icelandic National Planning Agency points out

that Landsnet‘s definition of protected areas is limited as it is based on the Nature Conservation

Register or on areas that enjoy local protection or cultural relic protection, according to the Regional

Plan for high temperature areas in Þingeyjarsýsla District 2007-2025. The definition does not consider

protection as a result of craters, pseudocraters or lava, in accordance with the regulations on nature

conservation (Article 37a), which reflects the government policy on protection. The landscape units

characterised by modern day lava (Þeistareykir Lava Field) are therefore categorised as having a rather

low value in Landsnet‘s assessment report. The Þeistareykir Lava Field is the youngest lava field within

the area, with unique craters, pseudocraters and lava channels and otherwise fulfils the stipulations of

the law on the protection of these types of geological formations. The Icelandic National Planning

Agency therefore does not agree with Landsnet‘s assessment of the value of the Þeistareykir Lava

Fields and believes that the area should be categorised with other landscape units in the area with a

rather high or high value. The Icelandic National Planning Agency also points out that the proposed

construction of a high voltage transmission line and trails across Jónsnípuskarð Pass will result in the

disturbance of the area in the northernmost part of Bunga. The Þeistareykir Lava Field will be divided

into two somewhat equally large areas and the overall view of the lava will be permanently altered.

The Icelandic National Planning Agency also believes that the lava is unique at the national level despite

its relatively small size. The area is also sensitive to changes and traces from trails and construction

pads will be permanent. The disturbance of the lava does not conform to government policy which is

reflected by the laws on nature conservation and the protection of geological formations is a priority

(policy on sustainable development in Icelandic society). The Icelandic National Planning Agency is

therefore unable to accept Landsnet‘s conclusion that construction on high voltage transmission lines

will have only a considerably negative effect on the landscape unit within the Þeistareykir Lava Fields

and believes that the effects on the lava will be significantly negative and irreversible.

The Icelandic National Planning Agency agrees with Landsnet‘s assessment that the experience of

outdoor enthusiasts by Höskuldsvatn will be considerably negative as a result of the high voltage


23

transmission line to the west of the lake, where outdoor enthusiasts will no longer be able to see an

untouched wilderness from areas like Höskuldsvatnshnjúkar. The Icelandic National Planning Agency

does not agree with Landsnet‘s assessment that the effects of proposed construction work on the

travels of outdoor enthusiasts and tourists who hope to enjoy a largely undisturbed environment will

be considerably negative. The Icelandic National Planning Agency points out that high voltage

transmission lines across Hólasandur and alongside the Kvíhólafjöll Mountains and Bæjarfjall Mountain

and up to Þeistareykir will run alongside rambling and riding trails in the area. Most organised trips to

the lowland area between Lambafjall (westward) and Gæsafjöll to Bæjarfjall (eastward) are planned

on the premise that participants will be able to enjoy the untouched wilderness. The Icelandic

National Planning Agency believes that the presence of the high voltage transmission lines in a large

part of the area and the location of the line across the Þeistareykir Lava Field will obviously significantly

affect the experience of ramblers and riders. The aforementioned research indicates that the

enthusiasm of outdoor enthusiasts and tourists for the Þeistareykir area will be lost. The presence of

high voltage transmission line will mean that the area can no longer be promoted based on the promise

of an untouched wilderness. However, other opportunities for tourism, based on easy access to the

area should develop as a result of the construction of the road from Krafla across Þeistareykir and up

to Bakki. The Icelandic National Planning Agency believes that visits to the area by ‘untouched natural

wilderness enthusiasts’ will decrease and that there is a danger that planned trips to the area will be

discontinued. There are no recent, accurate figures on the number of tourists of this type visiting the

area but research carried out by the Icelandic Tourism Research Center indicates that the area is mostly

visited by outdoor recreation enthusiasts and tourists. The Icelandic National Planning Agency

therefore believes that outdoor enthusiasts and tourists who wish to enjoy untouched wilderness

areas will be significantly, negatively affected by the proposed high voltage transmission lines. Tourism

agencies planning this type of trip will also be affected.

The Icelandic National Planning Agency agrees with the conclusions of the assessment report with

regard to the considerable visual impact of the high voltage transmission lines on the area surrounding

the lines (within 5 km of the lines). The Icelandic National Planning Agency points out that the

construction project is extensive: Each line will be 60 km in length, 375 transmission towers will be

raised and trails will be built up within the area. The Agency also points out that laying high voltage

transmission lines either side of the Lambafjall Mountains will affect more landscape units than if the

lines were to run alongside each other between Krafla and Bakki. Nine landscape units out of ten

which have been categorised as part of an untouched wilderness will be affected by construction work

and high voltage transmission lines will run through unique landscape areas, protected areas and

through lava areas that are protected according to the laws on nature conservation. The Icelandic


24

National Planning Agency also points out that the lines from Þeistareykir and across Jónsnípuskarð Pass

will have a negative impact on the experience of outdoor recreation enthusiasts and tourists in the

mostly untouched area from Hólasandur to Höfuðreiðarmúla and between Lambafjall (west) and

Gæsafjall (east). The Icelandic National Planning Agency believes that construction will disturb a large

area which is sensitive to change and that the effects on landscape and the physical appearance of the

area will be extensive. The Icelandic National Planning Agency believes that the aforementioned

combined effects of the proposed high voltage transmission line on the landscape, protection matters,

outdoor recreation and tourism will be significantly negative and will also have a visual impact.

3.3 EFFECTS ON GEOLOGICAL FORMATIONS

The assessment report shows that high voltage transmission lines will penetrate areas in the

northernmost part of Bungu in the Þeistareykir Lava Field which is unlike other areas in the country.

The line will also be in close proximity to an explosion crater in the Laufrandarhraun Lava Field in

Jónsnípuskarð Pass and will pass through areas covered in rock thrown from the crater. The lines will

also traverse an area 3 km to the south of the Guðfinnugjá Fault. The high voltage transmission lines

will be located in the periphery of the geothermal area in Þeistareykir which is on the Nature

Conservation Register due to the diverse geological formations in the area. The lines located further

south in Reykjahlíðarheiði will be 750 m from hot springs by Krókóttuvatn, approx. 3 km from the

crater by Hvannstóðshöfða and 1.5 km from Leirhnjúkar. The high voltage transmission lines will also

traverse the Leirhnjúkshraun Lava Field.

Material extraction plans expect all the materials for the construction of the high voltage transmission

line to be sourced from loose earth layers from the present day and from the end of the Ice Age ísaldar

(sandbanks in narrow gorges and glacial moraine or glacial sediment). The report states that 17 of the

27 proposed material extraction areas have a low or very low conservation value according to the

categorisation system of the Icelandic Road Association and proposed material extraction in these

areas will have a negligible effect on geological formations. The same categorisation system indicated

that several material extraction areas in Norðurþing have a high conservation value as a result of water

protection and not as a result of geological formations. Many of the areas have a medium conservation

value as they can be easily seen from busy areas. The effects of material extraction in these areas are

somewhat negative.

The assessment report also shows that disturbances to lava as a result of the construction of the high

voltage transmission lines will be unavoidable, including the Leirhnjúkshraun, Þeistareykir and

Bóndhólshraun Lava Fields (a total area of 5 hectares). However, Landsnet believes that the effect on

lava will be negligible, with the exception of the western part of Leirhnjúkshraun. There is a trail in


25

Leirhnjúkshraun where Krafla Lines 4 and 5 will be located and the lava to the west of the trail will be

disturbed by the construction of high voltage transmission lines. The lava area is undisturbed and the

impact of construction could therefore be considerable but localised in Leirhnjúkshraun.

The Environment Agency of Iceland believes that the assessment should include an analysis of the

effects of construction on individual geological formations rather than a general analysis of the extent

of the disturbance within the entire lava field area. The exact location of disturbances to lava is

important as well as an assessment on whether construction will divide the lava area into units. The

Agency also points out that the construction of a high voltage transmission line across Þeistareykir Lava

Field, the trails running alongside the lines and the construction of the power station road across the

lava field will divide the Þeistareykir Lava Field into units. Geological phenomena could create a

‘whole’ which would need to be protected e.g. crater rows, lava, lava channels, faults and fissures.

Relatively little disturbance to the area could therefore damage the conservation value of these types

of geological formations. Lava disturbed by construction generally has a lower conservation value than

undisturbed lava and construction work in lava areas should not be justified by the fact that the area

has already been disturbed. The Agency points out that the disturbance of geological phenomena as a

result of construction leads to a reduction in this type of lava environment and similar undisturbed

geological formations elsewhere therefore attain a higher conservation value. The Environment

Agency of Iceland points out that any disturbance to pahoehoe lava during construction is usually less

obvious than similar construction carried out in apal lava. However, smooth lava does not have a

lower conservation value than apal lava (according to the guidelines). The Environment Agency of

Iceland points out that the area where high voltage transmission lines will be constructed across

Leirhnjúkshraun, from Hvíthólaklif, is an area covered by coarse lava and the Agency believes that this

lava has a high conservation value. The construction of the high voltage transmission line will have a

considerably negative and irreversible effect on Leirhnjúkshraun and geological formations protected

according to Article 37 of the law on nature conservation have not been considered. The Environment

Agency of Iceland points out that there is no guarantee that contractors working on the construction

of high voltage transmission lines across Leirhnjúkshraun will use smaller machinery than the

machinery used for drilling. There is therefore no guarantee that the trails in the lava will be less than

those used for drilling purposes. It should therefore be assumed that construction will affect the area

to the same extent as the current trail in Leirhnjúkshraun and that construction will have a considerably

negative and irreversible effect on Leirhnjúkshraun.

Landsnet‘s response shows that the IEIS had taken the Environment Agency of Iceland‘s opinions into

account and had described any localised negative impact on the lava although the overall effects were

still the main focus (considering the size of the lava field). The construction of the proposed high


26

voltage transmission line will inevitably disturb the lava but the design of the structures was completed

with a view to minimising any disturbance to the lava. Landsnet points out that the current trail

across Leirhnjúkshraun was designed to carry heavy machinery used for drilling. Lighter machinery

will be used for the construction of the high voltage transmission line and this type of trail will therefore

not be needed in Leirhnjúkshraun. This should ensure fewer disturbances to the area than that caused

by the current trail. Landsnet will appoint supervisory bodies to ensure that this is the case. Landsnet

believes that the construction of the high voltage transmission line across Leirhnjúkshraun will have a

localised and considerable negative effect on the area affected by new trails (the western section of

the line across the lava) although the overall effects on the lava will be negligible.

The Environment Agency of Iceland points out that the hot spring area by Hitur has a high

conservation value, according to the assessment of the Icelandic Institute of Natural History. The

Environment Agency of Iceland believes that transmission towers should not be raised within the area

and the prevention of traffic disturbing the area must be ensured.

Landsnet‘s response outlines the fact that the assessment report states that raising transmission

towers in hot solfatara areas is not a feasible option. Measures will be taken to ensure that Hitur is

not disturbed and experts will be consulted as to the location and size of structures (later on in the

construction process) within areas that should be protected.

Birkir Fanndal states that laying an underground cable within the geothermal area by Næamaskarð

would be difficult and operating the cable would also be problematic. He raises concerns with regard

to the proposed route of underground cables alongside the Krafla Road in Hlíðardalur, which would

disturb a unique lava area in the valley even more than previous road construction. Jón Illugason

agrees with these conclusions and recommends that the underground cable be laid further east in the

valley from Dalleiri across Halaskóga and northward to the west of Halaskógafjall Mountain

Landsnet‘s response states that the Company will assess the possibility of laying the underground cable

elsewhere to protect the lava. Landsnet put forward a draft for the new location of the underground

cable during the development of the assessment report, in an area further east and outside the lava

area. The assessment report states that the changes will be announced to the Icelandic National

Planning Agency in accordance with the Environmental Impact Assessment Act no. 106/2000 “with

subsequent amendments“.

The Environment Agency of Iceland points out that the IEIS only refers to 12 material extraction areas

out of the 27 identified in the report and there is no clear indication that material extraction areas will

be limited to these areas. A detailed description of material extraction plans would be difficult at this


27

point but the IEIS should include information on which material extraction areas will be opened, which

will be closed as well as details on finishing work. The Environment Agency of Iceland also points out

that mines are expected to be distributed at a regular distance along the line route (3-6 km) and all

mines from proposed line route will be less than 1,5 km. The Environment Agency of Iceland believes

that the choice of material extraction areas should not be solely based on their distance from the

proposed construction area but also based on the visual impact of extracting materials from these

areas.

Landsnet‘s response notes that the appendix of the IEIS discussed 27 potential material extraction

areas, intended for use during the construction period and only gave 12 examples of material

extraction areas in the relevant municipalities. The material extraction areas are expected to fulfil the

material needs for construction so that new extraction areas will not need to be identified during the

construction period. Landsnet agrees with the Environment Agency of Iceland that material

extraction plans should be submitted for each area once construction work is imminent. The report

states that finishing work on the material extraction areas will be carried out in accordance with the

laws on nature conservation. The conservation value of material extraction areas was the deciding

factor in choosing material extraction areas. Shorter distances between material extraction areas lead

to less pollution and minimise any disturbance during the construction period.

The Icelandic National Planning Agency agrees with the Environment Agency of Iceland that the

overall effects of construction on lava with regard to geological formations is more important than the

overall percentage of disturbed land mass within the area (as assessed by Landsnet ). The Icelandic

National Planning Agency points out that construction may only affect a small part of the lava field but

the transmission line runs through an area with unique geological formations (Bungur) and will in fact

divide the lava field into two equally large units which will change the overall appearance of the lava.

Landsnet put forward two options during the preparation of the Regional Plan for high temperature

areas with regard to the route for Þeistareykir Line 1 (across Jónsnípuskarð Pass or north of

Höfuðreiðarmúla). Both options traversed the Þeistareykir Lava Field. The Icelandic National Planning

Agency believes that both options are in fact weak when the effects of construction on the lava field

are considered; both options divide the area, disturb unique geological formations in the lava and

transmission towers, trails and construction pads will have a significantly negative and permanent

effect on Þeistareykir Lava Field. The Icelandic National Planning Agency believes that there are no

satisfactory mitigation measures to reduce these effects. The Icelandic National Planning Agency

therefore believes that Landsnet should consider another option with regard to the transmission route

for Þeistareykir Line 1, which would run pass Höfuðreiðarmúla (see Chapter 2). The Icelandic National


28

Planning Agency agrees with the Environment Agency of Iceland and Landsnet that construction will

have a considerably negative and permanent effect on Leirhnjúkshraun.

The Icelandic National Planning Agency also agrees that underground cables alongside the Krafla

Road in Hlíðardalur Valley would disturb the lava in the valley even more. The Agency believes that

Landsnet should stand by its plans to assess the possibility of laying an underground cable to the east

of the lava in order to protect it. Any changes must be announced to the Icelandic National Planning

Agency in accordance with Article 6 of regulation No. 106/2000 “with subsequent amendments” and

Item 13a in Appendix 2.

3.4 EFFECTS ON CULTURAL RELICS

The assessment report shows that there are 60 relics within the affected area of the proposed

construction area for the high voltage transmission line, including 42 cairns. All the relics will be at

risk as a result of ground disturbance, human traffic and machinery: 44 will be at high risk, including

32 cairns, five mines/peat mines, two ruins, two walls and two sheep herding areas. The relics in

Þeistareykir are to the east of the area affected by the high voltage transmission lines and they are not

believed to be at risk.

The report states that contractors have been made aware of the location of archaeological remains

and arrangements have been made to protect these areas during the construction period. If the

protection of archaeological remains should fail, then the Archaeological Heritage Agency of Iceland

will be consulted. They will also be consulted if any new remains are discovered. Landsnet believes

that the effects of the proposed construction project on archaeological remains will be negligible.

The Archaeological Heritage Agency of Iceland points out that the IEIS does not cover two

archaeological remains in the Þeistareykir area which are described in the specialist report. The

Agency believes that all cairns should be marked within the proposed construction area to prevent any

unintentional damage to them. The following archaeological remains must be especially considered:

Þeistareykir land area: sheep gathering area (SÞ-250x: 046), Klif (SÞ-250x: 051, not referred to in the

IEIS), Þeistareykjaaðhald (SÞ-250x:056, not referred to in the IEIS), road/route (SÞ-250x:088)

and a ruin (SÞ-250x:096).

Bakki land area : wall (SÞ-312:033), peat mines (SÞ-312:054, SÞ-312:055, SÞ- 312:056, SÞ-312:057,

SÞ-312:058), ruin (SÞ-312:059) wall/irrigation (SÞ-312:061).

Landsnet‘s response outlines the reason that the archaeological remains in Klif and

Þeistareykjaaðhald were not included in the IEIS. The remains were not included because the proposed


29

line route was altered after a specialist report was submitted. The altered route meant that the

assessment of archaeological remains would need to be revie

Documents

Landsnet · 2017. 9. 5. · Author: ï¿½ï¿½Rut Kristinsdï¿½ttir Created Date: 9/5/2017 10:07:01 AM