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??