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The SOS Power Lines Platform, made up of some of the leading organizations involved in nature and bird conservation, including SEO/BirdLife, believes that the new regulations promised by the Ministry of the Environment and Natural Resources (MITECO) since the beginning of the legislative period should include some improvements to effectively reduce the deaths of millions of wildlife, including endangered species, caused by power lines (electrocution and collision) and wind turbines (collision and barotrauma). The platform emphasizes that these deaths are not accidental, but rather foreseeable and expected events that occur when the installation is dangerous for birds and lacks appropriate technical solutions to guarantee their complete safety.

In their submissions during the public comment period for the new royal decree, which closed on April 12, the entities belonging to the SOS Power Lines Platform believe it is essential to extend the obligation to implement corrective measures on power lines that pose a danger to birds to the entire country.

Currently, this obligation focuses on so-called Protection Zones, a legal entity already established in the 2008 Royal Decree on Birdlife and Power Lines currently in force. This legal entity is maintained in the draft decree released for public consultation. It includes the Special Protection Areas for Birds (SPAs) of the Natura 2000 Network, the areas of application of recovery plans for endangered birds, and, in general, the priority areas for these listed species. However, birds move throughout the territory, so limiting the adoption of measures to Protection Zones leaves an unaffordable number of power lines that pose a serious risk to birdlife outside the scope of the future Royal Decree.

The new regulation also provides for action on power lines located outside the Protection Zones, but only if there have been previous cases of electrocution or bird collisions confirmed by an authority officer. This measure is completely insufficient to guarantee that lines that pose a danger to birds will be corrected throughout the territory and, in any case, should not be limited to confirmed events but should also include situations of imminent risk.

Furthermore, the SOS Power Lines Platform believes that the creation of Protection Zones contradicts the Environmental Responsibility Law, a law that is higher than the Royal Decree, which establishes the obligation for operators, in the event of an imminent threat, to adopt appropriate preventive measures without delay and without prior warning. A Supreme Court ruling from October 2021 expressly states that the risk of bird electrocution is always immediate, regardless of whether the line is located inside or outside the Protection Zones.

In their submissions, the platform entities also request that specific timeframes be established to correct at least the most lethal lines or those that pose a high risk to endangered species, as otherwise, the corrections could be indefinitely delayed.

In recent years, we have witnessed rapid technological advancements in measures to correct and prevent the impact of power lines. Therefore, another of the SOS Power Lines Platform's calls for swift updates to the articles and annexes that describe these measures, preferably through ministerial orders. This will ensure that the best available technical solutions are always applied, without having to wait for a new amendment to the Royal Decree.

In any case, the entities comprising the platform believe that applying corrective measures after the fact is not enough, and that all new power lines must be built with bird-safe design criteria, minimizing risk from the outset.

The new royal decree expressly excludes power lines that supply energy to trains or other electrified means of transport. However, significant bird mortality has been observed on these types of lines, so the SOS Power Lines Platform believes they should not be excluded and proposes including in the new regulation the obligation to apply the technical measures for the protection of birds already established by ADIF.

One of the most positive new features in the draft royal decree is that it addresses the enormous problem of the current high mortality rate of wildlife at wind farms, both due to collisions (for example, in many birds) and barotrauma (in the case of bats), through measures such as shutting down wind turbines in situations of risk to these species and dismantling them.

The SOS Power Lines Platform applauds the importance given to this problem in the new regulations, although it proposes additional measures. Thus, detection and shutdown systems must be improved, as they have not been effective so far, especially in preventing the mortality of small birds and bats, which is increasing due to the massive installation of large wind turbines. Likewise, the use of trained dogs must be expanded to ensure the detection of carcasses and remains of animals that have fallen victim to this problem.

At the same time, the platform calls for the application of the principle of prevention and the avoidance of installing wind turbines in areas of high environmental sensitivity. To this end, it calls for the use and updating of sensitivity maps prepared by the Ministry of Environment and Natural Resources (MITECO) and organizations such as SEO/BirdLife and SECEMU, ensuring that the location of new projects does not endanger vulnerable bird and bat populations.

The SOS Power Lines Platform calls on the government to approve this royal decree, which the Ministry of Energy and Mines (MITECO) promised from the beginning of the legislative period, without further delay, and to include in the final text the changes proposed in the objections submitted by its member entities.

Furthermore, for the correct and effective implementation of the new regulations, the entities integrated into the platform demand uniform evaluation and action criteria throughout the state regarding the content of the royal decree, as there are currently significant differences in the interpretation and application of obligations in this area between autonomous communities. Among these criteria, they request that the owners of facilities, whether power lines or wind farms, be responsible for the maintenance and periodic verification of the status of the anti-electrocution and anti-collision measures applied.

Another proposal from the SOS Power Lines Platform is the creation of a technical monitoring committee, with representatives from the relevant authorities, the business sector, and scientific and civil society organizations, to assess compliance with the royal decree, propose improvements, and ensure its constant updating.

Finally, the SOS Power Lines Platform requests in these allegations that Miteco (Ministry of Energy) prepare periodic public reports on the implementation of the new royal decree, including data on corrections made to power lines, mortality recorded on both power lines and wind turbines, risk areas, and the evolution of bird and bat mortality.

Members of the SOS Power Lines Platform: Action for the Wild World (AMUS), Spanish Association of Forestry and Environmental Agents (AEAFMA), Ecologists in Action, Foundation for the Conservation of the Bearded Vulture (FCQ), Group for the Rehabilitation of Native Fauna and its Habitat (GREFA), Quercus Magazine, SEO/BirdLife, Iberian Society for the Study and Conservation of Ecosystems (SIECE) and WWF Spain.