SEO-Birdlife: When a key stakeholder acts as environmental consultancy, The Monlora III wind farm (V)

MITIGATION STRATEGY

In the end, we will refer to the mitigation strategy proposed. In the conclusions (one page) they do not provide an overall assessment /conclusion about the risk of the project to birds.

CONCLUSION 1:

Install cameras to detect and shut down the turbines. We must say that there are not currently any device in the market suitable for stopping any turbine and avoid collision with the blades.

SEO-Birdlife mentions the I+D Espartal wind farm in Aragón but any information about this wind farm and the shut down by cameras has been presented or peer-review evaluated to demonstrate it works. Thus, SEO-Birdlife leaves all the probabilities to random chances.

The only device in the market that has similar characteristics is the so-called "DTBird". We must highlight the recent review in the United States by the American Wind and Wildlife Institue, see a summary here DTBIrd evaluation And also the full report here DTBird evaluation full report

Basically, the DTBird has false positives (shutdowns that do not correspond with the target species) and failures in the detection and dissuasion modules that fail in stopping the turbines so endangered species may collide anyway. SEE THE REPORTS FOR THESE TECHNICAL ISSUES. In a conclusion, there is still a long way till these techniques work properly at wind farms to be effective.

CONCLUSION 2:

There is a need for a conservation plan for cliff-nesting raptors as the Bonelli´s eagle and the Egyptian Vulture. 

Referring to cliff-nesting and omitting the roost means is a contradiction by the authors but confirms the potential risk to species that "breed far from the projects" as the review of the SEO-Guidelines confirm. 

CONCLUSION 3:

They recommend fitting satellite transmitters to two Red Kite pairs. This should have to be done during the construction study. First to see what the habitat use is and, secondly to analyze by means of the BACI procedure. Fitting only after a wind farm has been built is only a way to keep a contract with the developer. 

The two other conclusions in the report are related to a conservation plan for the most threatened species and also post-construction monitoring. These ideas should have been developed much longer in the report and not in such a short and poor way.

MISSED REFERENCES

This is a minimum list of missed references in the report by SEO-BirdLife:

Arroyo, B., Ferreiro, E. y Garza, V. 1989. Inventario de la población española de buitre leonado (Gyps fulvus) y sus áreas de cría. Año 1989. Sociedad Española de Ornitología. Informe inédito para ICONA, Ministerio de Agricultura, Pesca y Alimentación. Madrid.

Atienza, J.C., I. Martín Fierro, O. Infante, J. Valls and J. Domínguez. 2011. Directrices para la evaluación del impacto de los parques eólicos en aves y murciélagos (versión 3.0). SEO/BirdLife, Madrid (translated into English as Guidelines for Assessing the Impact of Wind Farms on Birds and Bats (Version 4.0).

Bautista, L.M., J. T. García, R. G. Calamaestra, C. palacín, C.A. Martín, M. B. Morales, R. Bonal, J. Viñuela. 2004. Effect of Weekend Road Traffic on the Use of Space by Raptors. https://doi.org/10.1111/j.1523-1739.2004.00499.x Cons. Biol.

BOA. 2018. RESOLUCIÓN de 2 de agosto de 2018, del Director General de Energía y Minas, por la que se otorga la autorización administrativa previa y de construcción de instalación "Parque Eólico Monlora III" de 49,5 MW de Fuerzas Energéticas del Sur de Europa X, S.L., en Castejón de Valdejasa, Luna y Sierra de Luna. Fecha de Publicación: 21/08/18. Número de boletín: 161.

Del Moral, J. C. 2002. II Censo Nacional de Alimoche. La Garcilla, 112: 14-19.

Del Moral, J. C. y Martí, R. (Eds.) 2002. El alimoche común en España y Portugal (I censo coordinado). Año 2000. Monografía n.º 8. SEO/BirdLife. Madrid.

Del Moral, J. C. (Ed.). 2009. El buitre leonado en España. Población reproductora en 2008 y método de censo. SEO/BirdLife. Madrid.

Del Moral, J. C. y Martí, R. (Eds.) 2001. El buitre leonado en la Península Ibérica. III Censo Nacional y I Censo Ibérico Coordinado, 1999. Monografía n.º 7. SEO/BirdLife. Madrid.

H. T. Harvey & Associates. 2018. AWWI Technical Report: Evaluating a Commercial-Ready Technology for Raptor Detection and Deterrence at a Wind Energy Facility in California. American Wind Wildlife Institute, Washington, DC, 96 pages. Available at www.awwi.org. © 2018 American Wind Wildlife Institute

Iñigo A., Barov B., Orhun C., Gallo-Orsi U. 2008. Action plan for the Egyptian Vulture Neophron percnopterus in the European Union. SEO BirdLife

IUCN. 2019. The IUCN Red List of threatened species. https://www.iucnredlist.org/ Fecha de consulta: 10 de Octubre de 2019.

Madroño, A., González, C., Atienza, J. C. (Eds.) 2004. Libro Rojo de las Aves de España.Dirección General para la Biodiversidad-SEO/BirdLife.Madrid.

Martí, R. & Del Moral, J. C. (Eds.) 2003. Atlas de las Aves Reproductoras de España. Dirección General de Conservación de la Naturaleza-Sociedad Española de Ornitología. Madrid.

Scottish Natural Heritage. 2014. Recommended bird survey methods to inform impact assessment of onshore wind farms. 37 pp.

SEO 1981. Primer censo de Buitreras (1979). Ardeola, 26/27: 256-259.

SEO/BirdLife 2012. Atlas de las aves en invierno en España 2007-2010. Ministerio de Agricultura, Alimentación y Medio Ambiente-SEO/BirdLife. Madrid.

 Żmihorski, M., T.H. Sparks, P. Tryjanowski. 2012. The weekend bias in recording rare birds: mechanisms and consequences. Acta Ornithologica, Volume 47, Number 1: 87-94(8)

SEO-Birdlife: When a key stakeholder acts as environmental consultancy, The Monlora III wind farm (IV)

BIBLIOGRAPHY

After reviewing the technical report for the gaps detected, we will refer to the LACK OF SCIENTIFIC REFERENCES/BIBLIOGRAPHY that would help to support the conclusions and also to establish the mitigation strategy. Any pre-construction report should include the references to the Methodology, analysis or similar results from other projected areas. However, as previously said THERE ARE NO CITATIONS. 

We would like to remind SEO-Birdlife previous work they have been developing in the past:

A) EUROPEAN ACTION PLAN FOR THE EGYPTIAN VULTURE (2008)

In 2008 SEO-Birdlife was responsible to coordinate and prepare the Species Action Plan for the Egyptian Vulture /Neophron percnopterus/ in the European Union 

This document includes a specific section to threats (page 20 of the Action Plan): One of the main actions is to reduce the fatalities caused by wind farms. The Detailed Actions were: 

1.4.1. Develop risk assessment guidelines for planners, based on the latest Egyptian Vulture research data.

1.4.2. Improve EIA and pre-construction monitoring for proposed wind farms.

1.4.3. Block planned and remove existing wind turbines from sensitive areas (ca. 5-8 km radius
near active nest)
Applicable to: GR, IT, FR, PT, SP

In the Action Plan, that 1.4.2 highlighted the action above is clearly overlooked in this study. The threat of wind farm collisions was considered high for Spain at that time. Of course, SEO-Birdlife omits the Action Plan in the monitoring report; this would have relaxed the potential risks of the project for the people in charge of the Environmental consent. 

SEO-Birdlife cannot argue they were not aware of the roosting site. They directly asked the EBD (Estación Biológica de Doñana) to meet in person for the Action Plan and they knew it is the main research institution in Spain working with the EV. The argument "we were not advised" then it is unbelievable.

B) RED BOOK OF SPANISH BIRDS (2004) 

The Red Data Book of Spanish Birds was also prepared by SEO-Birdlife in 2004 and published with funds of the Spanish Ministry for the Environment. Red Data Book of Spanish Birds 2004   

Here the Egyptian Vulture is classified as ENDANGERED already. Also, the same status was for the Red Kite and the Bonelli's Eagle. The Montagu`s Harrier was VU. 

Again SEO-Birdlife omits to mention this book and thus favors the developer not opposing too much to the development.  

C) GUIDELINES FOR ASSESSING IMPACTS FROM WIND FARMS ON BIRDS (2014)

 In 2011 SEO-Birdlife published the only Best Practice Guidelines for the wind energy sector in Spain

This publication by J.C. Atienza et al. (V4.0) explained in detail the gaps and needs of improvement for studies related to wind energy and birds, regardless of being an ESIA or a bird study. SEO-Birdlife fails in the same mistakes:

c.1- Page 14-15: "only 29% of studies take into account the Red Data Books": Here SEO-Birdlife omits the Spanish Red Data Book as seen above.

c.2- Page 15: "Studies are focused only in the wind farm footprints, without considering birds that may breed far away from such as vultures"   SEO-Birdlife does not take into account any of the Breeding bird Atlases available and also the National counts they coordinate for years: Egyptian Vulture breeding surveys 2000, 2008, 2018 or Griffon Vultures 1979, 1989, 2008, 2018 some of the just published.

c.3- Page 15: "studies do not consider the cumulative impacts of neighboring projects": We have said this before.

c.4-Page 16: "Previous studies lasting at least one year should be carried out. Bird behavior and use of airspace are affected by the wind direction. Previous studies have been shown not to assess this variable properly, resulting in an underestimation of the fatality rate"  The study is only descriptive, does not provide wind measurements that are of course available from the developer, and any kind of analyses.

c.5- Page 16 has a full section about this: "Fragmentation of projects – Assessment of synergistic impacts" We have referred to this before. There is a complete miss of such information at the Monlora wind farm study. We encourage the reading of this section in the book to see how many gaps exist in the monitoring report.

c6.- Page 30: Another section about what infrastructure comprises a wind farm: "Definition of a wind-farm project". For SEOBirdlife "The following factors should, therefore, be taken into account in any wind-power project environmental assessment:
1) Wind turbines
2) Interconnection network to the ETS
3) Electricity Transformation Substations
4) Access roads
5) Control post (if necessary)
6) Transmission power line to grid connection"

 All these elements must, therefore, be assessed as a whole to avoid committing a fragmentation of projects running counter to European law. Moreover, all wind turbines separated by a distance of fewer than 2000 meters have to be considered as a single project, as well as all the farms whose administrative authorizing procedure is carried out at the same time within the same municipal district and pumping their energy into the same grid connection point.

SEO-Birdlife could argue this is not an EIA (Environmental Impact Assessment). However, these are variables to be factored in the impacts of birds species, which should be also considered in the pre-construction bird monitoring. There may occur collisions with the powerlines.

c7.- Page 32.- Has a Table where they define what does High sensitivity means for a project. Among the selected criterion, there is the following list that is met by the Monlora wind farm for sure:

•  "That the zone is frequented by species of bats or birds listed as Vulnerable (vulnerable), Sensibles a la Alteración de su Hábitat (sensitive to habitat alteration) or En Peligro de Extinción (In danger of Extinction) in the State (or regional) Catalogue of Threatened Species." The project meets this.

• That the zone is frequented by species of bats or birds listed as En Peligro de Extinción (In danger of Extinction) or En Peligro Crítico (In Critical Danger) in the Libro Rojo de las Aves de España (Red Data Book of Birds of Spain)." The project meets this.

•   That within 5 km of the zone there are large breeding colonies or roosts (herons, skuas, gulls, terns and waders, seabirds, raptors, etc.) Obviously, the project meets for the Egyptian Vulture.

According to the guidelines, the Monlora wind farm would be in a High sensitivity area but SEO-Birdlife omits any reference to this manual. They consider the mitigation proposals are enough to move the project forward. According to the capacity 49.5 MW and Table 4 in the guidelines: "Farm size assessment factors on the basis of the number of wind turbines and their capacity, with the aim of establishing the potential impact on bats and birds. Only possible combinations with present technology have been indicated", it would be considered "medium".


c.8- Page 34: Section "Determination of the area affected" Here there is a lot of guidelines about potential impacts on vulture species that have not been considered, i.e. (Are there nests of big eagles or Egyptian vulture or roosts of Egyptian vulture in a 15 km radius around the zone selected for the projected wind farm?)

Special heed should be paid to distribution in the vicinity of pairs of Spanish imperial eagle, golden eagle and Bonelli’s eagle. A check should also be made for any breeding populations or communal roosts of Egyptian vulture. WHERE IS THIS SPECIAL CHECK ABOUT THE COMMUNAL ROOSTS?? There was not "special check", as the roost was only 300-500 m from the nearest turbine and information was omitted.

c.9- Page 34 and following: SEO-Birdlife establishes the steps that need to follow any study to properly assess the impacts. The most important section is called "Information Culling Procedure". During Phase 2 of the process, they encourage the use of bibliography available.

 Phase 2 - Compiling of existing information   

• Environmental impact studies from other projects They should have asked for information related to Monlora I, II, IV...
  
• Environmental monitoring plans from other wind-farm projects The same as the previous point
• Ornithological yearbooks There are in Aragón and are well known by everyone
• Atlases and libros rojos (Red Data Books) SEO-Birdlife has published the Atlases of Breeding Birds and wintering birds plus the Red Data Book
  
• Government reports 
•  Scientific information All scientific papers have been omitted.

c10.- The most surprising is that SEO-Birdlife lists many reports as references for this book, many of them belong to the Aragón region. None has been used in the Monlora wind farm study. Even at the end of the Guidelines, SEO- Birdlife lists the number of individuals that have been found beneath the turbines so they have precise information about the current impact of wind farms in Aragón. Why they did omit this review??

 

SEO-Birdlife: When a key stakeholder acts as environmental consultancy, The Monlora III wind farm (III)

DATA ANALYSIS TO INFORM THE WIND FARM RISKS

The list of protected species according to either the National or Regional regulations appears in the Figure 1. After the Latin name there are the Spanish and Regional catalogue's classifications.

Figure1. List of protected species at National/regional level in the study area

This list is quite complete. However, SEO-Birdlife DID NOT FOUND AN EGYPTIAN VULTURE ROOSTING SITE DESPITE IT WAS ONLY 300  m!! (THREE HUNDRED) METERS OF A PLANNED TURBINE) ¿? WHY?  This roosting site existed for more than 20 years now, it was monitored by the Doñana Biological Station-National Research Council (EBD) since then. SEO DID NOT ASK  EBD, OMITTING ALSO ANY CONSULTATION PROCESS as is mandatory /fair in any good study. WHY THEY DID NOT ASK? It has to be its own initiative if they presume of a well renowned environmental organization.

Photo: Egyptian Vulture roosting site located 300 m from the nearest turbine that was never monitored. SEO-Birdlife argues nobody warned them of its presence (J.A. Pinzolas)

CUMULATIVE IMPACTS: 

The report OMMITS ANY REFERENCE to other joining projects in its vicinity suc as Monlora I, Monlora II, Monlora IV ... Normally, developers SPLIT BIGGER PROJECTS INTO SMALLER ONES < 50 MW to avoid the Environmental consent be informed by the National Government instead by the Regional one. 

This is noteworthy, as SEO-Birdlife has been very active for years now fighting at Courts against wind farm project fragmentations: 

-  Parques Eólicos Montánchez 2019 

-  Omaña y Cepeda 2012 

-  Vilalmeca Area 2018 

THESE ARE THREE EXAMPLES WHERE SEO-BIRDLIFE OPPOSSES TO WIND FARM FRAGMENTATION. They do not mention anything about the remaining Monlora projects although. SEO Birdlife published in 2014 (Atienza et al. ,2014)   The Guidelines to Assess impacts by wind farms  Page 16 of this document deals with the fragmentation concern. They could argue this project it is not an EIA (Environmental Impact Study) but they were developing this pre-construction monitoring as if a single wind farm would be planned.   
WHY NOT SEO BIRDLIFE DID MENTION THAT OTHER WIND PROJECTS WERE PLANNED IN THE AREA? The developer was the same so it cannot be justified they did not know.


The argument this is only a bird study is not a fair one; any study about potential impact of birds at wind farms should include such kind of related issues that, in the end, affect the magnitude of project impacts.

DECISION ON THE PROJECT: After the study SEO-Birdlife concludes Monlora III Wind farm is a GO PROJECT

   

SEO-Birdlife: When a key stakeholder acts as environmental consultancy, The Monlora III wind farm (II)

 We now comment the findings of the pre-construction monitoring programme, as, in our opinion, it lacks completely of an appropriate assessment according to the Best practice international standards.

RESULTS OF THE STUDY: 

SEO-Birdlife just lists in a Table the number of contacts per species and the equivalent passing rate (birds /hr) = number of contacts /1,040. The first conclusion is really obvious: THE HIGHER PASSING RATES ARE FOR THE SPECIES WITH THE HIGHER NUMBER OF CONTACTS. Figure 1.

Figure 1. Extract of Table 5 in the report. List of species and passing rates (birds /hr). The most advanced of the analyses they made.

 This is the "most advanced" analyses SEO has performed with the data, calculating just % for every Table they provide. But if page 27 says there were 520 hours of monitoring, SOMETHING IS WRONG : i.e. 28 Hieraetus pennatus contacts divided by 1,040 give a passing rate of 0.025 birds per hour as the Figure 5 says. This division should be by 520 that is exactly the half of 1,040 so passing rates in the Table should be the double.

The second conclusion comes after splitting the number of contacts according to the flight directions, Figure 2 Shows also part of Table 6 in the report, just sorting the observations and their percentages. The heading includes "Meses" but it is unclear to what this refers to.  

Figure 2. Table 6 in the report showing the percentage of flights according to each direction for all species.

From this Table, they conclude 2: THE PRIMARY FLIGHT DIRECTIONS ARE SW-NE and NE-SW. Very informative if we consider that the most abundant bird recorded is the Common Crane (Grus grus) totaling 1,488 birds. We have to reckon the reader that this is the common pattern twice per year, as the C. crane winters in Extremadura SW Spain, returning in the end of the winter to Europe (300,000 cranes each year). There is no other conclusion about the flight, namely for the Endangered species that should be a subject of concern.

Finally, they shortlist the FLIGHT ALTITUDES PER SPECIES, again percentage of flights below, through the Rotor Area and above the Rotor, Figure 3. 

Figure 3. Table 7 in the report showing flying heights

Results are not surprising, less birds would fly below the rotor < through the rotor < above the rotor because  of a very simple reason the height intervals at which they measure the flying height follow the same trend so flights should be at least proportional. For any turbine the height from the ground to the bottom of the blades (A) is much smaller that the rotor diameter (B) and of course any height above the turbine (C), Figure 4. 

Figure4. Source: https://www.zmescience.com

SEO_Birdlife calculates the RISK OF THE WIND FARM BASED JUST IN THOSE SPECIES WITH > 10% OF FLIGHTS AT ROTOR SWEPT AREA.

Findings of the bird monitoring STOP here!!!! in the report. Really Amazing if being a renowned consultancy...

SEO-Birdlife: When a key stakeholder acts as environmental consultancy, The Monlora III Wind farm (I)

After the worldwide crisis Spain is under new wind developments again. This opens again the potential impacts to endangered species and habitats. A surprising case is that of Forestalia in Aragón province, where the local Government has consent several projects near Ejea de los Caballeros.  The area supports populations of sensitive species that require of appropriate pre-construction studies for birds and bats.

There, SEO-Birdlife, the Spanish Partner of Birdlife International, acted as the environmental consultancy hired by the developer. SEO-Birdlife agreed the project is a go one despite its potential impact to the ENDAGERED Egyptian Vulture (Neophron percnopterus). Given the sensitivity of the site and the species involved we make this peer review, trying to answer and understand the quality of such report and its conclusions. 

Below, Figure 1, the cover of the study entitled: "Delivery: Avifaunal study of Monlora III Wind farm. Luna, Sierra de Luna and Castejon de Valdejasa municipalities" November 2018, 32 pages.  

Figure 1. Front cover of the study

 The fieldwork was developed between December 2016 and November 2017. It is signed by Luis Tirado, Biologist and SEO representative in Aragón region for the last 11 years at least ( www.seo.org). Page 3 in the report mentions that other biologists participated, but the "human team" as the report says is not mentioned, neither the number of people involved nor their names.  

First question to know is: HOW MANY PEOPLE AND WHAT THE SKILLS OF THOSE INVOLVED WERE? 

   

 We are going into the details of the study through the methods, findings and conclusions.

Methods

 "Monlora III" Wind farm received its environmental consent by an official Resolution published in the Official Gazzette of Aragón Environmental consent August 2018 . It has thirteen turbines and a total power output of 49.5 MW.

SEO-Birdlife established 20 Vantage Points (VPs) over the entire area, the project itself and its surroundings, Figure 2. The superimposed grid has squares of 500 m side each. 

Figure 2. Map of the study area. VPs: black triangles, Turbines: red dots. The grid has squares with 500 m side each.

They made 52 visits (1 per week). The dates provided in the report shows that fieldwork was made during the weekends, ALL THE DAYS OF MONITORING/FIELDWORK WERE SATURDAYS.  

It is well known that time in the week affects the bird behavior. In this case SEO misses important scientific references on this matter such these papers in Conservation Biology or Acta Ornitologica. There are of course much more references, easy to find through scholar google including terms such as "weekends", "raptors" or "disturbance". For a Society that has a Scientific Committe, this should be a must whilst planning the fieldwork. 

The total number of monitoring hours was said to be 1,040 hr., Page 15. However, THESE HOURS INCLUDED ROAD TRANSECTS OR OTHER KIND OF TRANSECTS, probably displacements between VPs (these methods are not described in the report) so it remains unclear HOW MUCH TIME DID THEY DEVOTE TO EACH SPECIES /GROUP AND NOT JUST TO THE VP WATCHING.  

They should explain the species specific methodologies and the time of each activity and not include the overall magnitude.

Further insight into the report gives more clues. In page 27, when referring to the results and analysis, they said 520 hours were spent in monitoring (10 hrs. /day). This contradicts what said above about 1,040 as the five hundred and twenty represent only the 50% of what the report stated in page 15. If they used 20 VPs, then they monitored just 26 hrs. per VP (See what the Scottish Natural Heritage says in its guidelines Vantage Point surveys, hours of monitoring and even more, when people from Birdlife Cambridge criticized this and also suggested further monitoring time in an international scientific Journal such as IBIS is Modelled sensitivity of avian collision rate at wind turbines varies with number of hours of flight activity input data

If they spent 26 per VP over a whole year (52 visits) we could calculate the hours per vantage point and visit = 30 minutes. This is clearly well under the international best practice requirements for wind farm pre-construction studies. This number, also makes us to doubt of how many people were really involved in the monitoring.  

SEO does not take into account the minimal requirements to them; otherwise as a worldwide organization they ask developers much more fieldwork. Is it an intentional omission or just a lack of knowledge?