VATTENFALL LETTER OF OBJECTION TEMPLATE

Please email this template to the below email address to lodge your opposition to Vattenfall’s plans to build a second windfarm in the Clashindarroch. Feel free to amend or add as you see fit and to put your personal thoughts in it.

GroupInternalAudit@vattenfall.com

TEMPLATE

FAO: Head of Corporate Legal and Integrity

Vattenfall AB

SE-169 92 Stockholm, Sweden

STOP CLASHINDARROCH II WINDFARM, ABERDEENSHRE, SCOTLAND

I write as a concerned supporter of the petition by Wildcat Haven
C.I.C in connection with the above development promoted by Vattenfall Windpower
Ltd at the Clashindarroch forest, Aberdeenshire, Scotland.

We recognise and support the need for renewable energy and
Vattenfall’s mission for “fossil-free living within one generation”. However,
for the reasons that follow, we are writing to draw your attention to the
issues with this proposed development which now risks causing the extinction of
the Scottish wildcat in the wild and seriously damaging Vattenfall’s
reputation:-

• In its simplest terms, this is the wrong development in the wrong place – the Clashindarroch is
       home to a vital population of the critically endangered Scottish wildcat (felis
       silvestris), which is strictly protected by European and International
       law. Wildcat Haven has identified some 13 individuals present within the
       forest from its field work to date. This is a conservation matter of
       national and international importance and there is no confidence at this
       time that this development will not have a significant negative
       (indeed, potentially catastrophic) effect on the wildcat population
       resident within the forest;

• Your subsidiary, Vattenfall Windpower Limited, is failing to comply with the environmental
       rule of law in relation to the proposed development – in particular, in
       down-playing its environmental impact assessment for the project. Where
       proven, this is a criminal offence under national law.

• There are moreover concerns about the propriety and structuring of lease payments between
       Vattenfall Windpower Limited and the Scottish Government (your company
       accounts disclose that the Clashindarroch I scheme links lease payment to
       MWh generation constituting an effective joint venture arrangement without
       statutory authority);

• Crucial environmental information requests that would cast light and transparency on these
       issues are being refused by both Vattenfall and domestic competent
       authorities;

• Overall, Vattenfall Windpower Limited’s actions fail to uphold the important sustainability
       standards which Vattenfall AB has itself committed to by virtue of the OECD Guidelines for Multi-national     enterprises.

On 3 December 2019, Wildcat Haven wrote to your Head of
Environment and Sustainability Unit (based in Germany) to express its concerns
with a view to avoiding, or at least minimising, the need for litigation. This
led to a meeting in February this year where Wildcat Haven met with project
representatives of Vattenfall Windpower Limited in Edinburgh in an effort to
draw attention to these issues and promote serious recognition of them. This
meeting was only accepted after the application for consent had been submitted.
Regrettably however, to date Vattenfall Windpower Limited has not provided
responses to the agreed action points from that meeting (including, answers to
whether key documentation would be shared to support the exercise of legally
guaranteed public participatory rights in the consenting process. This includes
access to key ecological base-line data etc). This falls far short of the
standards of environmental stewardship expected of a company like Vattenfall
and its own mission statement.

Wildcat Haven CIC’s petition against this development is now the
biggest wildlife petition in the UK ever (with over 700,000 signatures)
showing the substantial public interest and support for maintaining this
population in situ.

We support Wildcat Haven’s letter of objection to the section 36
application for consent under the Electricity Act 1989 (which can be accessed here) and are writing to draw Vattenfall AB’s attention to this compliance
issue. We urge you to intervene to ensure compliance with your own group
standards and stop this development before it risks causing the extinction of
the Scottish wildcat in the wild.

Yours