League for the Protection of Nature’s comment regarding the Public Consultation of the Environmental Impact Assessment of the São Miguel do Pinheiro solar plant
The São Miguel do Pinheiro Solar Plant Project covers an implantation area of about 703 ha, to be occupied by several integrating infrastructures of the solar plant. The project is in the Mértola municipality, in the union of parishes of São Miguel do Pinheiro, São Pedro de Soli and São Sebastião dos Carros. The project also includes the construction of a very high-tension electrical line (MAT), at 400 kV, with approximately 18.6 km length, to be implemented in a corridor that covers the municipalities of Mértola (union of parishes of São Miguel do Pinheiro, São Pedro de Solis and São Sebastião dos Carros), Alcoutim (Martim Longo parish) and Tavira (Cachopo parish).
The project proponent of the São Miguel do Pinheiro solar plant project is Fermesolar, Lda.
As referred in the EIA technical report, under Decree-Law nr. 152-B/2017, of 11th December, the project is not located in a Classified Area. However, the same report mentions that, according to the “Manual to support the analysis of projects regarding the installation of distribution and transport of electrical energy aerial lines”, corridors of MAT lines marginally overlap with a very critical area for steppe birds, corresponding to the Birds and Biodiversity Important Area (IBA) of São Pedro de Solis. This marginal overlap and its surroundings cover open habitat spots considered potential habitats for the occurrence of steppe birds, namely, the great bustard (Otis tarda) and little bustard (Tetrax tetrax), for which mortality by collision with electrical lines is known (LPN, 2013; Marques et al., 2008), including with lines from this type (Marques et al., 2005), and considered one of the main threats to the conservation of these species. Furthermore, mortality by collision with aerial electrical lines is not limited to the breeding areas, since these species move to other areas (Alonso et al., 2019; Rocha, 2006). This information should therefore not be underestimated because, in this context, movements from these species between these areas are probable to occur, resulting in mortality by collision with an aerial electrical line.
Still regarding the location of MAT line corridors, it is also important to mention that the Iberian imperial eagle (Aquila adalberti) nests about 7.5 km from the proposed corridors for the MAT line, which, despite not being considered a very critical/ critical area according to the ““Manual to support the analysis of projects regarding the installation of distribution and transport of electrical energy aerial lines” (ICNF, 2019), is considered relevant information and thus should be considered. Additionally, the intersection data of marked individuals of this species in Portugal, highlight movements intersecting the MAT line corridor, in a polygon (roughly) defined by Penedos and Carredoura, and Castelhanos and Roncão, south, that, therefore, suggest this area is used by juvenile/ immature individuals (unpublished data LIFE Imperial/ ICNF).
Regarding the mapping of highly critical areas for steppe birds, birds of prey and other birds, available information dates from 2009 and outdated in relation to the current population and distribution situation of the mentioned species, with emphasis to the Iberian imperial eagle and to the great and little bustards. Updated information that reflects the current situation of the referred birds is therefore needed.
Considering the existence in the vicinity of a wind farm, an assessment of the cumulative impacts of these two energy production infrastructures and their associated electrical lines should be performed.
The promotion of renewable energies proposed by photovoltaic projects is beneficial, but considering the high number of projects being developed without being supported by land management, it is urgent that governmental entities carry out a more comprehensive assessment of the potential impacts of these types of infrastructures (including corridors connecting the energy transportation and distribution networks), aiming at minimizing the negative environmental impacts that these can generate in certain areas with greater sensitivity.
Although this photovoltaic plant is not located in a Natura 2000 Classified Area nor in a Protected Area, it partially covers an area identified as IBA and the very-high voltage electrical line will cross part of this IBA.
The very-high voltage electrical line foreseen for the transportation of energy produced can have significant impacts on birds, especially steppe birds like the great and little bustard, since they move between areas that will be crossed by this future electrical line (namely Castro Verde SPA, Guadiana Valley Natural Park and S. Pedro de Solis IBA).
Considering the current decline observed in some of the steppe birds, namely in the great and little bustard (Silva et al., 2008; Gameiro, 2015; Alonso et al., 2019) and in the present context of climate change, it is necessary to ensure that the occurrence areas and corridors between occurrence areas of these species have good habitat management.
Thus, given the sensitivity of the area crossed, the minimization measures for the Electrical Line must include at minimum intensive signaling of the electrical line with the placement of anti-collision devices of type rotated Fireflies type (BFD’s) (that must be regularly replaced, if needed, to ensure effective signaling) or, alternatively, burying the electrical lines or the establishment of a route that does not cross areas with high ecological value like this IBA. It should also be ensured long term monitoring of the electrical lines to assess the impact of the new electrical line in the birds’ mortality and also on the population trend of the species, especially steppe birds, that must also comprise the analysis of the movements of marked birds to better understand the corridors they use.
Measures to increase the rapine birds’ prey, like wild rabbit and partridge, should also be foreseen in the implantation area of the solar plant.
It is LPN’s understanding that compensation measures that foresee the maintenance and increase of suitable areas for the IBA of S. Pedro de Solis steppe birds should be included, with support for farmers who promote an agriculture compatible with the conservation of these species. To this end, an adequate compensation measure for the negative impacts caused by this project (also considering the cumulative impact associated to the wind farm already existent) will be the classification of the S. Pedro de Solis IBA as a SPA (Classified Natura 2000 area). This way, this territory would start to have the legal protection needed to ensure conservation of protected and threatened birds that occur in this territory and it would allow the creation of agri-environmental measures to support the farmers who perform agricultural practices that are beneficial to biodiversity.
LPN also points out the negative social impact associated with the large expansion of solar parks in the interior that could contribute to increasing depopulation of these already abandoned areas. For that, it is necessary to create adequate policies that support farmers who stay in these interior areas and who practice an agriculture that promotes biodiversity, but that is hardly competitive compared to the renting values that solar parks are offering.
Given the expressed above, LPN considers that the São Miguel do Pinheiro solar plant project should have an unfavorable technical opinion. If this solar plant is approved, it is imperative to ensure that all the minimization and compensation measures listed above, including the classification of the S. Pedro de Solis IBA as SPA, are implemented.
5 Februrary 2020
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