Articulo 1. Equipo1 Se

Energy Policy 158 (2021) 112525
Contents lists available at ScienceDirect
Energy Policy
journal homepage: www.elsevier.com/locate/enpol
In search of wind farm sustainability on the Yucatan coast: Deficiencies and

public perception of Environmental Impact Assessment in Mexico
Ezequiel Zárate-Toledo a, Paul Wood b, 1, Rodrigo Patiño c, *
a
ENES-Mérida, UNAM, Yucatan, Mexico
b
Independent Environmental Consultant, Yucatan, Mexico
c
Cinvestav – Unidad Mérida, Yucatan, Mexico
A R T I C L E I N F O A B S T R A C T
Keywords: Through the analysis of the corresponding Environmental Impact Assessment (EIA) for five wind projects set up
Environmental policies on the Yucatan coast, in Mexico, this work seeks to draw attention to the environmental controversies that these
Wind farms projects generate. To carry out our analysis, we resorted to three sources of information that are part of the EIA
Renewable energy
process: (i) the Environmental Impact Statement (EIS), presented by private companies, for these wind farms; (ii)
Public participation
Environmental impact assessment
observations and criticisms of the EIS, presented by the civil society during the public process to which the EIS is
Environmental controversies submitted; and (iii) the rulings emitted by the federal environmental authorities. This documentation was
complemented by participation in a number of forums and some interviews. Based on this analysis, we defined a
series of deficiencies in the EIA process. Accordingly, we can affirm that in Mexico, as in other countries, there is
no wind energy plan capable of reconciling energy objectives with nature conservation. Renewable energy
projects in Mexico have been designed solely based on the distribution of wind or solar resources, completely
ignoring environmental or social issues. In this regard, a sustainable energy transition requires strengthening the
environmental management capabilities of governments, and the application of mechanisms that will allow the
integration of environmental variables in the early stages of decision making, using instruments such as the
Strategic Environmental Assessment.
1. Introduction are divided in two camps; pro- and anti-renewable energy, creating a
situation where usually allied forces are attacked by arguments that
Since 2007, most of the wind farms proposed in Mexico have come from within their own ranks.
propitiated diverse scenarios of territorial and social conflict (Zárate
Toledo et al., 2019). According to some authors, this situation is
1.1. Environmental Impact Assessment and conflicts over renewable
repeated in many parts of the world in such a way that it seems that the
energy projects
energy transition itself is beset by conflict (Colvin et al., 2016; Larsen
et al., 2018; Devine-Wright et al., 2020). The way in which renewable
In the context of social struggles and opposition in which renewable
energy is developed may often anger citizens, causing the energy tran
energy projects are being developed, Larsen et al. (2018) point to the
sition to lose legitimacy, along with the political capital that it should,
Environmental Impact Assessment (EIA) as a decisive step in the process
theoretically, enjoy. An important component of the opposition to
of achieving social acceptability. The EIA has been identified as an in
renewable energy is due, ironically, to environmental concerns, and it
strument which can ideally reduce conflicts and risks in the planning
has been characterized in the literature by the expression “Green on
processes of renewable energy projects. It is believed to open a funda
Green” (Warren et al., 2005). This means that while renewable energies
mental space for public discussion about projects, allowing compliance
may produce global benefits in the fight against climate change, they
with democratic decision-making processes (Schumacher, 2019). How
also generate local environmental impacts, specifically on the landscape
ever, the EIA may cause disputes, without the possibility of reducing
and biodiversity. For that reason, says Warren, environmental groups
developer uncertainties or the risk of projects being blocked (Larsen
* Corresponding author.
E-mail address: [email protected] (R. Patiño).
1
Our colleague and friend Paul Wood passed away in 2020 during the revision process of this manuscript; this paper is dedicated to his memory.
https://doi.org/10.1016/j.enpol.2021.112525
Received 27 July 2020; Received in revised form 19 April 2021; Accepted 17 August 2021
Available online 3 September 2021
0301-4215/© 2021 Elsevier Ltd. All rights reserved.
E. Zárate-Toledo et al. Energy Policy 158 (2021) 112525
et al., 2018): in some cases, citizens perceive that their interests are not 2. Conceptual framework: the conflicting nature of the EIA
represented in the process; in other cases, the process generates a
negative resident perception of the behavior of the authorities. Finally, Environmental controversy is described here as some kind of
from the opposite perspective, the EIA has been seen as a deficient in disagreement between two or more parties, through which the parties
strument in wind farm planning (Smart et al., 2014). perceive a threat to their environmental needs, interests or concerns
(Callon et al., 2009). Due to the number of environmental controversies
1.2. Research aims derived from the EIA process worldwide, an examination of the litera
ture reveals a profound crisis in the effectiveness of these evaluations
In this work, the environmental controversies generated by the and their participatory mechanisms. It becomes clear that in some
installation of wind farms on the Yucatan coast in Mexico are analyzed, countries the EIA process allows the different parties involved in a
together with the role of the EIA in the regulation of such conflicts. In project to define a number of topics or concerns, and also provides some
recent years, the Yucatan Peninsula has had the fastest growth in wind mechanisms for requesting supplementary information related to the
and photovoltaic projects in Mexico (a list of 40 projects that have been project, as in the case of Mexico. However, there are a number of critical
proposed during the last 10 years in the region is presented in Appendix voices questioning these implemented methodologies and the usefulness
I). Analyzing the installation processes within the renewable energy of data generated from these processes (e.g. CEFAS, 2010). In this re
industry in this region reveals the need to look for mechanisms that gard, a number of authors (Côté et al., 2017; Cashmore et al., 2010;
harmonize planning and nature conservation. Richardson, 2005) highlight some of the gaps commonly observed in the
The text is organized as follows. First we define the theoretical dis EIA process. In the first place, due to serious deficiencies in the meth
cussions surrounding the EIA. Next, we describe our methodology and odologies employed, the EIA is not designed to fully identify the envi
our particular case study. Finally, we elaborate on our analysis, pointing ronmental problems or challenges that the projects present. This
out the gaps present in the EIA process, the controversies that arise in negatively affects the authorities’ capacity to make informed decisions
civil society and how they are treated by the public administration. about the projects’ impacts. Moreover, information on the procedures
followed by analysts is often less than transparent, while the lack of
1.3. Importance of this study standardization makes it impossible to compare impacts between sites.
This lack of clarity in the mechanisms of evaluation generates an at
The importance of this study lies in the fact that Mexico, along with mosphere of arbitrariness that destroys public trust and questions the
other Latin American countries, started out some years ago as one of the validity of the authorities’ decisions. This spurs the public to prepare
world leaders in the diffusion of renewable energy technologies, buoyed documents refuting the results of impact studies (Callon et al., 2009).
by the growing demand for electricity, both nationally and interna
tionally. It has been reported that experimentation and innovation in 2.1. Crisis of the rational planning model
renewable energy are greater in Latin America than on other continents
due to the quantity and variety of projects underway (Bresciani, 2019). Some authors associate this crisis with the rational planning model.
Although some national governments include strict environmental According to the principles of “positivism”, this model focuses on the
regulations for individual renewable energy projects at the local level construction of a “rational” procedure that is based on the analysis and
(Vaissière et al., 2014), globally, energy scenarios include limited con knowledge of facts verified or proven by scientific experience. This
siderations of environmental consequences beyond those associated planning model has a decisive effect on defining the role of the actors in
with greenhouse gas emissions. These scenarios do not consider envi the procedure. It divides actors into (i) the experts and decision-makers
ronmental externalities, especially regarding national and international (bearers of technical and scientific knowledge), and (ii) the general
legal obligations and commitments on biodiversity and other local public. This sets up a potential conflict between, on the one hand, the
environmental issues (Hooper et al., 2018). This problem is particularly rationality of well-informed actors and, on the other, the irrationality
important in view of the fact that many of these countries, like Mexico, and ignorance of the public (Côté and Waaub, 2012; Ortiz, 2020).
are among the most bio-diverse on the planet. The number of wind and However, it is considered that although the EIA relies on a rational
solar parks projected for this country will mean increasing pressure on procedure, that is, on the systematic identification and analysis of the
its biodiversity and natural protected areas. In this article, we highlight consequences of a project on the environment, the evaluation of its
the problems involved and emphasize the need for improving our importance in terms of impact is inevitably subject to interpretation. As
knowledge base in order to achieve better environmental stewardship Limoges et al. (1993) point out, the subjects submitted to the verdict of
during the energy transition. the experts are topics on which simple and unambiguous answers cannot
Despite the fact that EIA is a fundamental tool at the project level, be given. According to these authors, given the current state of scientific
where many of the conflicts manifest themselves, there is a lack of knowledge there are areas of uncertainty whose meaning remains open
publications analyzing the role of EIA in relation to conflicts over to debate. In this way, confrontation between rationality and irratio
renewable energy projects. In addition, most of the existing literature nality, or between knowledge and ignorance, can be avoided and
focuses on analyzing the EIA regulations and procedures required by replaced by different interpretations, even of what is or is not rational in
legislation, especially on how public participation is managed (see e.g.: a context of uncertainty. For that reason, according to these authors, the
Schumacher, 2019; Schwertner et al., 2019). This article will add EIA must be subject to debate or public scrutiny. This is not only for the
knowledge on contradictions related to specific content –particularly on purpose of validating the conclusions of the report, but also analyzing
the environmental issue-in the EIA process of five wind projects in the set of procedures of the EIA, specifically at the level of the identifi
Yucatan which have been approved by the federal environmental au cation of environmental problems and their structuring in terms of
thorities. We analyze the gaps in the EIA regarding sensitive ecosystems, impact assessment. Indeed, as the empirical experience of this work
the way they are seen and highlighted by citizens, and the position of shows, there is a strong demand from citizens to participate at all levels
public authorities regarding these disputes. Finally, although the case of the decision-making processes: in the identification of the problems
study focuses on the coast of Yucatan, we believe similar problems arise and the choice of criteria for evaluating the impacts. It can therefore be
in other parts of the world, suggesting that the conclusions are more concluded that public participation mechanisms are insufficient for the
widely applicable. integration of actors’ opinions about projects.
2
2.2. Hypothesis world (Zárate Toledo et al., 2019). Indeed, the largest set of wind farms
in Latin America currently operates there. However, this region has also
The specialized literature on EIA provides a series of analyses high been recognized as one of high biodiversity.3 This situation has gener
lighting the deficiencies of the most common methodologies for ated fierce controversies around the development interests of renewable
analyzing impacts. It also offers a number of ways to overcome these energy projects. According to some authors, the ineffectiveness of the
deficiencies. In this paper, we attempt to analyze the controversies in the mechanisms for evaluating environmental and social impacts contrib
processes of evaluation of the environmental impacts of wind farms in a uted to a massive social protest that led to the blockade - between 2012
specific ecosystem: the northern coast of Yucatan, and the role of EIA in and 2016 - of several different wind projects in the area (Howe et al.,
controversy management. Our hypothesis is to affirm that, contrary to 2015; Zárate Toledo and Fraga, 2016).
what is intended, the EIA in Mexico - as in other countries - does not The political and social conflict generated in this region forced the
“provide effective means to integrate environmental factors into plan Mexican authorities to apply new instruments focused on improving
ning and decision-making procedures, so as to reduce to a minimum the social participation and respecting the human rights of indigenous
negative consequences for the environment” (Atienza et al., 2011). After communities. These instruments are the Social Impact Assessment (SIA),
more than ten years of approving renewable energy projects, the and the Free and Informed Prior Consultation for indigenous commu
Mexican environmental authorities have not created the necessary in nities.4 All these measures are part of the so-called 2013 Energy Reform,
struments to guide companies to generate better environmental impact which also included a series of auctions for electricity companies,
studies and improve public participation in these processes (Zárate mainly aimed at the use of renewable energy.
Toledo et al., 2019). Addressing these deficiencies is a crucial step to However, as different studies have indicated (Zárate Toledo et al.,
wards achieving social acceptability. 2019; Zárate Toledo and Fraga, 2016; Howe et al., 2015), the problem
with these instruments - including the EIA -, which contain minimal
3. Description of the case study, methodology and discussion mechanisms for social agreement, is that they are generally performed
after the granting of key permits, such as that for electricity generation,
3.1. Application of the EIA in Mexico issued by the Energy Regulatory Commission (CRE), and connection to
the national electricity network granted by the Federal Electricity
The EIA is an important component of public environmental pro Commission (CFE), the public body that dominates the electricity mar
tection regimes. Through it, the initiators of the projects seek to obtain ket in Mexico. Both permits are issued without taking environmental
prior authorization to carry out activities likely to have an impact on the criteria into account, thus illustrating that technical and economic
environment and society (Fortin, 2009). In Mexico, the EIA is defined in criteria prevail over social and environmental ones, as we will see in the
Article 28 of the General Law of Ecological Balance and Environmental present case study. In this regard, we can say that the EIA does not carry
Protection2 (LGEEPA, 2015) as the procedure through which the Federal any weight on the stakeholders for energy planning, since there are no
Ministry of Environment and Natural Resources (SEMARNAT) “estab guidelines on what developers need to consider will influence regula
lishes the conditions to preserve and restore ecosystems faced with tors’ decisions, among other criteria.
works and activities that may cause ecological imbalance, or exceed the In 2015, the new Law of Energy Transition (LTE, 2015) tried to
limits and conditions established in the applicable provisions to protect include social and environmental criteria in decision-making for energy
the environment”. Articles 30, 34, and 35 of this law define the planning. This law established the legal obligation of the SEMARNAT to
administrative procedures through which the EIA is performed. The EIA conduct a Strategic Environmental Assessment (SEA) in regions of the
starts when the company or person who intends to develop a project, country with high potential for renewables.5 Despite the importance
delivers to the SEMARNAT an Environmental Impact Statement (EIS), a that the SEA could have for stakeholders, the Mexican government has
document that describes the project, indicating associated environ not developed it. This has now led to a demand from civil organizations,
mental and social impacts. The EIS is placed under public scrutiny, communities and academic groups that see the SEA as an opportunity
during which written opinions or suggestions from the public, experts, that would allow the incorporation of environmental and social vari
and local authorities may be received. Subsequently, a public informa ables into the initial stages of decision making (Patiño, 2018). These
tion meeting can be requested and held. The SEMARNAT may also ask groups believe that the SEA could help resolve the deficiencies and
companies for additional information, or other government offices for regulatory loopholes of the EIA and improve spatial planning. As we will
particular opinions, before final publication of the official ruling. The see below, the absence of a SEA in Mexico prevents the imposition of
ruling falls into one of three categories: approved, approved with con generic corrective measures for a group of projects with similar char
ditions, or rejected. acteristics, and also excludes the points of view of citizens and local
Only 10 years after the implementation of the EIA in Mexico, authorities from the energy transition process.
Bojórquez-Tapia and García (1998) reported that the EIS, in general,
tended to contain rather inadequate descriptions of the environment,
and a biased and subjective assessment of impacts. Therefore, the EIA 3.3. Materials and methodology to analyze environmental controversy
reflected implicit values and failed to address the environmental con around the EIA processes for wind farms in Yucatan
troversy likely to be generated by the projects. The application of the EIA
in renewable energy projects has highlighted these deficiencies. The state of Yucatan, in the Southeast of Mexico, is recognized as a
3.2. Application of the EIA in a contested regulatory framework

3
A report from the World Bank states that “the southern Isthmus of
The Mexican wind industry first encountered the EIA during 2007 Tehuantepec is a world-class bird migration corridor, through which millions of
birds pass each year as they move between North America and Central or South
within the framework of the so-called Isthmus of Tehuantepec Mega
America” (Ledec et al., 2011, p. 104).
Wind Project, an ambitious project in which an infrastructure of 4
The Consent of Indigenous Populations and the SIA are stated in Articles
2000 MW of installed capacity was between 2008 and 2012 in the south 119 and 120, respectively, of the new Law of Electric Industry (LIE, 2021),
of the Isthmus of Tehuantepec, considered one of the windiest in the which was firstly published in 2014.
5
The SEA is “an instrument of prevention, designed to integrate environ
mental aspects into the planning and decision-making phases and into the
2
The LGEEPA was firstly published in Mexico in 1988, and has been public plans and programs that could have significant effects on the environ
reformed several times until the most recent modification in 2015. ment” (Atienza et al., 2011, p.19).
3
region rich in biodiversity, extensively protected by a number of nature the topic in the national and local public agenda, and the commentaries
reserves (Durán García and Méndez González, 2010). In 2012, the in from the variety of actors (private companies, consultants, non-
terest in installing the first wind farm in the Yucatan coastal area pro governmental organizations, academics, activists, people from the
voked strong social opposition related to a controversial change in the affected communities) participating in these forums, were contrasted
territorial planning of the Yucatan coast (Zárate Toledo and Fraga, with 13 interviews that were carried out with specific actors (Appendix
2016). Since then, more than 20 large-scale photovoltaic and wind farms III). Among EIS public information meetings, forums and interviews, 12
have been proposed (Fig. 1) in the state of Yucatan, and social opposi transcriptions were performed in order to systematize the different
tion has increased, causing the judicial suspension of some of these opinions.
projects. In this context of struggles, the EIA has become a lively sce
nario of confrontation between companies, organized civil society 4. Discussion
groups and public authorities.
In the following sections, we analyze five wind projects on the Based on the analysis of the materials listed in section 3.3, we
northern coast of Yucatan (Fig. 2), whose EIA have been authorized by describe a series of deficiencies and gaps present in the EIS documents -
SEMARNAT (Table 1). These five projects were proposed within a these were listed in the first block of Table 2 when apply for all wind
corridor some 200 km in length, where an ecological and territorial projects in Table 1. These information and regulatory gaps condition the
planning program (POETCY) had previously been enacted to protect the measurement of impacts and the general results reported in the EIS
local valuable environment of the Yucatan coast. We decided to focus documents. Many times, it is a matter of the absence of guidelines,
the analysis on these projects because most of the environmental ob regulations or laws that could guide the preparation of impact studies.
jections are concentrated here, due to the fact that the proposed Many of these deficiencies are present in other countries, as reported by
installation of most of these wind farms lies within conservation areas some authors (Ledec et al., 2011; Atienza et al., 2011; Kuvlesky et al.,
defined by the POETCY. 2007; Vaissière, 2014). Taking into account these deficiencies, and
To carry out this research, we used three sources of information from based on the literature on this topic, we highlight five analytical
the EIA process: frameworks (the second block of Table 2) that indicate the main con
(i) The EIS documents submitted by the private companies, (ii) the sequences of these regulatory gaps.
comments presented by civil society at the time of the public consulta One of the factors that produces discontent among citizens is the
tion on these EIS documents, and (iii) the resolutions issued by the procedures that the companies use to define the places where they seek
federal environmental authorities. to set up these projects. Globally, Nadäi (2007) identified the preemi
nence of two fundamental criteria: good wind quality and the feasibility
(i) Environmental Impact Statement (EIS) of connecting the parks to the electric grid. This means that wind farms
are often proposed in areas with fragile ecosystems and of importance
An EIS is a document prepared by a consultant, paid for by the pri for the conservation of biodiversity (Ledec et al., 2011; Kuvlesky et al.,
vate companies interested in developing a project, which describes the 2007; Warren, 2005). Some authors attribute this phenomenon to wind
impacts of proposed activities on the environment. In this work, eight planning problems that are often followed by the
EIS documents were consulted, including those of the five projects listed decide-announce-and-defend scheme, and propose participatory plan
in Table 1, and some others which were not authorized by the ning and impact measurement methodologies (Fortin, 2009; Wolsink,
SEMARNAT. 2007), which some countries in Europe have adopted (Vaissière, 2014).
On the other hand, some authors refer to the problem of defining the
(ii) Comments presented by civil society during the public area of influence of the projects -and therefore of measuring their im
consultation pacts-, as one of the most recurrent problems in EIS documents (Atienza
et al., 2011), although some countries have also implemented directives
These are structured compendia of observations and objections - –not always well-to correct these deficiencies (Vaissière, 2014).
both written and oral - that civil society (academic groups, environ Another more pressing problem at the international level arises from
mentalists, local residents, NGOs) presented, including public informa the limitations of the EIA when it comes to studying the cumulative,
tion meetings, when public consultations were opened by environmental synergistic and residual impacts of wind farms. Many factors influence
authorities as part of the EIS process. These collective comments point this problem: deficiencies in the definition of the area of influence of the
out some gaps and technical deficiencies in the EIS. The five wind pro projects, lack of evaluation of the impacts at the regional level, frag
jects described in Table 1 were placed under public scrutiny and the mentation of the impact studies for the same project (e.g. presenting
corresponding comments were analyzed in this work, together with impact studies of transmission lines and sub-stations, separated from the
those related to two photovoltaic projects (see Appendix II). The docu wind turbines, or of different phases for the same wind project), low
ments show how citizens express dissent and contain the most repre quality of studies and little field work done to collect information on
sentative public observations and questions that can be applied to all affected sites, few studies on the impact on other species, beyond birds
wind farms that have been or are intended to be installed on the Yucatan and bats. On the other hand, there are few published monitoring studies,
coast. and many times they show that only a small percentage of wind turbines
are monitored, making it difficult to estimate the real impact of the wind
(iii) Rulings emitted by the federal environmental authorities farms (Ledec et al., 2011).
Furthermore, one of the major problems that besets the EIS at the
The rulings contain the authorization granted by public environ international level is the lack of quality control of impact studies, as
mental authorities (SEMARNAT) at the end of the EIA process, estab recognized in some European Commission documents cited by Jalava
lishing conditions, recommendations and measures that companies must et al. (2010), and Atienza et al. (2011). The low quality of the impact
adopt to protect the environment. The approvals issued by the SEM studies can lead to an erroneous environmental impact statement since
ARNAT to the five wind projects were made conditional on a number of the relevant organs base their decision on inadequate information. In
mandatory actions to be undertaken by the companies. this regard, some authors acknowledge that at the European level the
In addition to these documents from the EIA processes, we have situation is uneven: there are countries that have advanced in the
participated in a series of academic and other public forums in which the development of guidelines and standardization of impact study meth
social and environmental impacts of renewable energy projects were odologies, although deficiencies prevail in their application (Vaissière,
discussed (see Appendix II). The 13-forum list reveals the importance of 2014; CEFAS, 2010). In the case of countries that have not developed
4
Fig. 1. Identified projects for large-scale wind and photovoltaic farms in Yucatan.
Fig. 2. Natural reserves and identified projects for large-scale wind farms in Yucatan’s northern coast.
transparency is recognized in the monitoring of impacts by companies

Table 1
and environmental authorities, and therefore the effects are under
Wind farms analyzed in this work.
estimated, as recognized in a study by the World Bank in Mexico (Ledec
Project Installation Status (April Use CREa EIAa et al., 2011).
capacity (MW) 2021) (POETCY)
Dzilam 72 In operation Conservation 2014 2014 5. Results: deficiencies of the EIA for wind projects in Yucatan
Bravo
Sinanché 151 Project Conservation 2015 2017
Progreso 90 In operation Conservation 2015 2017
5.1. Inadequate criteria used for determining site location and deficiencies
Tizimín I 86 In operation Exploitation 2016 2017 in defining the area of influence of the projects
Tizimín 76 and in 2018 2021
II expansion The Yucatan coastal zone is defined by specialists as “a complex
Chicxulub 71 Project Conservation 2016 2018
ecosystem of great biodiversity formed by lagoons and a band of
a
Years in which the projects obtained authorizations for electricity generation
- from the Energy Regulatory Commission (CRE)-, and EIA’s authorization by the
SEMARNAT.
measures to improve the quality of impact studies, the authorities’

opinions are rhetorical, seeking to correct deficiencies that should have
been resolved before project planning. In many cases, a great lack of
5
Table 2 arbitrary nature of the process for updating this instrument (Zárate and
Technical deficiencies and regulatory gaps identified in the EIA processes for Fraga, 2016).
wind farms on the Yucatan cost, and analytical frameworks proposed for this Facing these problems, companies seek to defend themselves by
study. arguing that they take scientific sustainability criteria into account when
Deficiencies and information gaps when reporting environmental impacts choosing their site. In the case of the Chicxulub wind farm, the EIS states
that: “different criteria were analyzed to achieve a sustainable and
- No detailed guides for developing the Environmental Impact Statement
technically viable site” (INECOL, 2018, p. II-927). These criteria
- Lack of official norms specifying technical criteria for installing wind farms
- No definition of maximum number of energy farms in a region included wind resources, access roads, the electrical grid,
- Lack of information on ecosystems and biodiversity socio-economic aspects and environmental viability. The first three
- Fragmentation of the projects and their evaluation criteria, the most important for the promoters, are fully covered. How
- Analysis of cumulative and synergetic impacts with other projects is missing ever, the socio-economic aspect is dispensed with rather simplistically,
- No transparency regarding residual impacts of the projects
and in the space of only two pages, by claiming that “the production of
- Lack of studies covering impacts to fauna as a whole or to the emblematic species at
the site (e.g. birds, bats, felids) electricity will bring important social benefits”. In terms of environ
- The impact of roads inside the wind farms is not considered mental viability, the EIS states that “the project is considered to be
- The impact of noise or vibration on the ecosystem is minimized environmentally friendly since it generates minimal waste and does not
- The visual and landscape impacts are not a priority
emit greenhouse gases into the atmosphere.” (INECOL, 2018, p. II-93).
Analytical frameworks or interpretative lines
In other words, they repeat the familiar industry mantra that wind en
- Inadequate criteria used for determining site location and deficiencies in defining ergy is, by its very nature, environmentally friendly.
the influence area of the projects Several civil society groups questioned this point during the corre
- Inability to study cumulative, synergetic and residual impacts sponding public consultation, emphasizing that “the mere fact of using
- Imbalance in the quality of information among the different EIS documents and lack
wind technology does not, in itself, guarantee the environmental
of standardization of methodologies
- Ineffectiveness of the regulatory norms applicable to the territory and repetition of viability of the farm” (Articulación Yucatán, 2018, p. 5). In the same
ecological slogans way, it was not considered possible to justify the installation of a wind
- Lack of consistency in EIA rulings emitted by environmental authorities and the farm on a site close to the coastal zone and the mangrove areas of in
impossibility of monitoring long-term impacts
fluence (Articulación Yucatán, 2018, p. 2). These same groups also
questioned the idea that the location of the site had been determined by
a scientific procedure since “the EIS did not present a detailed analysis of
Table 3 alternative sites” (Articulación Yucatán, 2018, p. 3). In that sense, it was
Decrees and conservation programs applicable to the territory of wind farms on pointed out that the installation of the park contravenes criterion 65 of
the Yucatan coast. the POETCY, which “indicates that the development of the wind in
Birds Land ecosystems Water ecosystems Mangroves dustry will be carried out preferably on agricultural land” (Articulación
- Important area - Priority - Priority Marine - Mangrove Site Yucatán, 2018). Note that it is implied that agricultural areas are of less
for bird Terrestrial Site Site for with Biological value to wildlife, as discussed above. Therefore, if we consider that “the
conservation for Biodiversity Biodiversity Relevance and entire Yucatan Peninsula has wind characteristics (i.e. wind distribution
(AICA) Conservation Conservation Need for
and intensity) classified as excellent and good for obtaining energy",8
- Important Bird - Priority Land - Priority Marine Ecological
and Region Region Rehabilitation
and that “there is a vast area for agricultural activities in the region”, it is
Biodiversity - Priority - Ramsar Site not clear why the development of the project was proposed near coastal
Area (IBA) Hydrological areas and mangroves (Articulación Yucatán, 2018).
- Area of Region Among the many deficiencies of the EIA is the lack of a regulation
endemic birds
that would indicate how to measure the area affected by the project or
how to define the so-called “Regional Environmental System”. De
wetlands consisting of mangroves, pastures and forests” (Euán-Ávila velopers take advantage of this vacuum by claiming that no environ
et al., 2014, p. 27)6; some of these characteristics are resumed in Table 3. mental impact occurs beyond the spaces occupied by the different
For this reason, and due to the deterioration that this area was experi elements of the project. For instance, the EIS for the Progreso wind farm
encing, in 2002 the Yucatan state government launched a territorial claims that the impacts are limited to the specific sites where the towers
planning program, the POETCY, which was officially decreed in 2007 are installed; in contrast, an area of direct influence of 100 m is defined
(POETCY, 2007). in the Regional Environmental System, although it is not explained why
However, by 2014 the interest of the wind farm industry in installing 100 m is acceptable (CAM, 2017, p. II-5).
projects on the Yucatan coast had drastically modified environmental In another project, the EIS asserts that “the park will only occupy
policy. Anxious to attract multi-million dollar investments, the Yucatan 28.08 ha, which represents 0.079% of the total surface of the Regional
state authorities modified the POETCY to accommodate large-scale Environmental System” (Consultores en Ecosistemas, 2016, p. 109). In
renewable energy projects. This provoked a heated response in the ac this regard, it is established that “although the project proposes to use
ademic community and civil society, who protested and denounced the only 3.3% of the total land area, this will be permanently occupied”
(Consultores en Ecosistemas, 2016, p. 270). For this reason, it is stated
that “this type of project does not cause fragmentation of the habitat”.
Thus, the EIS goes on to affirm that the impact on the Regional Envi
6
Due to their high biological productivity and their importance in stabilizing ronmental System “will be insignificant since more than 96% of the
the coastline, over the last four decades, several areas of the coastal ecosystem property – which consists of cattle pastures-, and the current conditions
have been declared natural protected areas at both the national and state levels, to which the fauna is adapted, will remain unchanged” (Consultores en
while some are also listed as “Ramsar” sites – an international convention for Ecosistemas, 2016, p. 228).
the conservation and rational use of wetlands, adopted in 1986 by the Mexican
government, which entails the commitment to establish conservation policies
and sustainable management of the resources found there (Ramsar, 2021).
7
Moreover, the whole Yucatan coast is considered as an important area for bird To facilitate the location of quotations in the EIS and other related docu
conservation (Área de Importancia para la Conservación de las Aves, AICA), as ments, we quote the original page system of each document.
8
recognized by Bird Life International and the North American Bird Conserva See for instance: https://cleanenergysolutions.org/fr/resources/wind-re
tion Initiative (CONABIO, 2021). source-map-mexico.
6
It is often assumed by consultants, companies, and even environ contains some basic information that is absent from the latter.
mental authorities, that cattle pastures and agricultural areas have little The EIS for the Chicxulub wind farm includes a relatively robust
to no value for wildlife. However, extensively farmed ranches can har characterization of the environmental system in which the wind farm
bor many birds and other animals, particularly when patches of forest or would be installed. It describes in detail the regulations applied to the
corridors of trees are maintained as part of the habitat matrix. For territory, although there are also omissions. Similarly, the study de
example, the endemic Yucatan Wren (Campylorhynchus yucatanicus), has scribes the components of the wind farm as well as the associated con
adapted well to overgrown cattle pastures in the region and these may struction work: it mentions the location of the wind turbines and the
provide an alternative to its more customary coastal habitat, which has electric substation, and it indicates the route of the transmission lines,
been destroyed or fragmented by increasing urbanization and the con although it does not assess the impact of the infrastructure. From a cu
struction of beach homes (Serrano-Rodríguez et al., 2018). Thus, mulative point of view, it presents information on the different wind
regarding cattle pastures and agricultural areas as being of no value to farms that are programmed in the region. It presents a series of good-
wildlife is a serious mistake that has no basis in fact. quality maps which indicate the features of the territory and the man
agement plans. It presents a series of tables where the areas affected by
5.2. Inability to study cumulative, synergistic and residual impacts each component of the wind farm are broken down, temporarily and
provisionally. It presents many tables and detailed monitoring infor
As mentioned in the previous sections, the absence of a SEA for mation of birds and bats that had been collected over the previous year,
Yucatan makes it impossible to determine how many projects can be although there is no complete information on the monitoring of other
programmed in this territory, as a function of the region’s ability to species present in the ecosystem, such as felids (INECOL, 2018).
sustain them. This makes it difficult for each project’s EIA to consider In contrast, the EIS for the Progreso wind farm, among other omis
cumulative, synergistic and residual impacts of wind farms, since each sions, does not present good-quality maps, nor a detailed description of
project is evaluated individually. To make matters even more compli the present and future activities in the territory, such as transmission
cated, wind farm developers are allowed to present a separate EIS for the lines, real estate developments, pig farms, communication routes,
wind farm itself and another EIS for the transmission lines needed to quarries, or other renewable energy projects that will be developed in
connect to the national grid. the area (GeoComunes, 2019). All of this is despite the fact that the place
This is the case, for example, of the wind farm currently operating in where the wind farm is intended to be installed is close to the industrial
Dzilam de Bravo. In the EIS for this farm, the project developers state zone of the port of Progreso, an area of high environmental value which
that “due to its size and level of impact, the transmission line will be the has already been impacted. The EIS for this project does not describe in
subject of an additional study that will be evaluated independently” depth the current regulatory systems that apply to the territory. On the
(Copremia, 2013, p. II-15). In regard to this problem, during the public other hand, this EIS establishes that it was not possible to carry out a
consultation process, civil society organizations and academic experts one-year monitoring of the species that make up the environmental
pointed out that “analyzing the environmental impact of the wind farm system to be impacted, but that such studies will be carried out when
without considering the environmental impact of one of its main com “the authorizations allow the release of the project investment” (CAM,
ponents, does not make any sense … [and] is completely inconsistent, 2017, p. V-13). The environmental authorization was granted by the
because it does not show the Project in its entirety, nor does it allow the SEMARNAT in 2017 and the project has been under construction since
evaluation of the impacts in an integral and cumulative way” (CEMDA, 2019, but we were unable to verify if the monitoring has been carried
2013, p. 22). out.
A similar case of project “fragmentation” can be seen in the Tizimín Because their ability to fly may result in fatal collisions with the rotor
wind farm, in operation since 2019, for which separate environmental blades of wind turbines, birds and bats receive special attention in the
authorizations were made for the wind farm itself and for the trans EIS.10 Nevertheless, glaring inconsistencies and discrepancies are found
mission line, both authorized in 2017 (Pontones and Ledesma, 2016a; from one study to the next. For instance, regarding birds, the EIS for the
SCGI, 2017). Moreover, in September 2019, a new EIA was proposed for Dzilam wind farm states that 149 species were identified, belonging to
a second phase of the wind farm, increasing its installation capacity from 19 orders, 49 families and 116 genera (CAM, 2017, Chapter IV, p. 41).
86.1 MW to 162.3 MW, and also increasing the territorial occupation These data contrast strongly with those reported in the EIS of the
from 1725 ha to more than 3 thousand hectares (INGESA, 2019). In Sinanché wind farm, close to that of Dzilam, which presents the results
summary, there are strategies of fragmenting EIS for wind farm projects, of the bird monitoring carried out over a period of one year. The EIS of
making it impossible to evaluate potential impacts in relation to other this projects states that “field work was carried out with an annual
projects in the same region, in relation to different components of the sampling, in which the most representative months for wildlife regis
same project, or in relation to a subsequent expansion of the same tration were selected (September, November, February, March, June
project. and July),11 especially of birds and bats, both resident and migratory”
(Pontones and Ledesma, 2016b, p. IV-95), although it should be noted
5.3. Imbalance in the quality of information among the different EIS that there are no migratory bats in Yucatan. Based on the collection of
documents and lack of standardization of methodologies this information, it was stated that: “at the project site, birds represented
the most abundant variety of species” (Pontones and Ledesma, 2016b, p.
Analysts point out that another common problem with EIS docu IV-102). “71 species grouped into 14 orders and 29 families” of birds
ments in Mexico is that they are mostly based on pre-existing biblio were found (Pontones and Ledesma, 2016b, p. IV-108).
graphic information, rather than exhaustive fieldwork (Articulación
Yucatán, 2018; CEMDA, 2016; CEMDA, 2013). Although there is an
official guide to conducting the EIS, this is very general, and does not 10
In general, the information in an EIS about the effects on other types of
define methodologies or statistical analyses.9 The consequence of this is
fauna such as felids, or the flora, is scarce or even null.
a huge disparity in the depth and quality of each EIS. For example, in the 11
In fact, affirming that these are “the most representative months” is an
case of the Chicxulub and Progreso wind farms, both authorized by the arbitrary decision that is not supported by the monitoring data or by the
SEMARNAT, while the former has some deficiencies in its content, it also bibliographic information. For example, April, May, and October were skipped,
although they are the most important months for bird migration. In contrast,
the data in the EIS for the Chicxulub wind farm show why annual monitoring
9
The guide can be consulted at the following link: https://www.gob.mx/cm should include every month, and that the passage of migratory birds is so
s/uploads/attachment/file/121011/Guia_MIA-Regional.pdf. variable that monitoring should be permanent during the months of migration.
7
When comparing the data from the EIS documents for the Dzilam and karstic surface of the peninsula and its underground aquifer (Mor
Sinanché wind farms, the second reports less than half of the bird species eno-Gómez et al., 2019). In this case, criterion 65 in the POETCY es
recorded in the sampling presented in the former, even though the area tablishes that “this area - the coastal strip that we refer to in this
for the Sinanché project is more than twice that of the Dzilam wind farm. document - is suitable for artisanal stone extraction without the use of
In the opinion of some specialists, the low number of species reported in excavation machinery or explosives, and industrial extraction of stone
the EIS for the Sinanché wind farm reveals that the monitoring was not material is not allowed” (POETCY, 2014). Faced with this regulation, the
performed with the intensity or frequency required (CEMDA, 2016). EIS for the Dzilam wind farm established that “the excavations for the
Another possible reason for the disparities in data from one document to foundations will be carried out using techniques that avoid damaging
another is the use of different methodologies since no standardized the soil and subsoil structure” (Copremia, 2013, p. II-24), without
methodologies have yet been established by the relevant authority, the establishing what these techniques might be. Given this, the decision of
SEMARNAT. Indeed, this makes it impossible to compare data from the SEMARNAT establishes that “in accordance with what was stated by
different EIS documents and negates the possibility of monitoring future the promoter, the project will not extract stone material; likewise, no
changes in the same place, or of establishing cumulative effects at the explosives will be used for excavation work (SEMARNAT, 2014, p. 35, p.
regional level. 35)”. That is, the authority affirms something that the company does not
In addition, the EIS for the Sinanché wind farm includes a particu guarantee: that explosives will not be used for excavation work. In the
larly questionable statement. It affirms that “during the field trips no end, the POETCY criterion 65 was not respected, since excavation ma
flocks of migratory birds were observed passing through the project chinery was used.
site”, claiming, therefore, that “the site where the wind farm is to be Despite the serious omissions and flaws described in this paper, the
located is not on a well-defined or established migration route” (Pon EIS all agree that wind farm projects do not generate a significant impact
tones and Ledesma, 2016b, p. IV-254). Industry proponents of wind on ecosystems. Statements made in this regard poison the public debate
power, as well as some authorities, often argue that since there are no by neglecting environmental impacts. These claims echo the slogans that
studies that define precise migration routes through the Yucatan affirm that renewable energies are, by their very nature, environmen
Peninsula, the projects will not affect migratory birds. This conveniently tally friendly. In the case of the Chicxulub wind farm, for example, the
ignores the fact that the Peninsula, in its entirety, is an important EIS states that although “the entire project falls within the “Ichka
crossroads for migrants flying south in autumn and north in spring, as ‘Ansijo” Important Bird Area (IBA), and occupies 23.99 ha of the Priority
well as being a vast wintering ground for dozens of migratory species Site for Conservation of Biodiversity number 5185, in addition to being
(Bayly et al., 2018; Deppe et al., 2015; Smith et al., 2001). located within the “Ring of Cenotes” Priority Hydrological Region (RHP)
Moreover, despite the fact that most of this migration takes place at number 102 and the “Sisal-Dzilam” Priority Marine Region (RMP)
night, none of the EIS documents reports night monitoring for migratory number 61, the project will not generate “a significant impact on the
birds, nor the use of essential instruments such as radar or acoustic ecosystem” (INECOL, 2018, p. II-5).
monitoring techniques, the only way in which migration can be quan However, we can counter this argument based on the deficiencies of
tified. For that reason, the National Commission for Biodiversity in monitoring and the lack of information surrounding all the wind and
Mexico (CONABIO) advises against the installation of wind farms in the solar parks that could be installed in the area. Indeed, affirmations about
region, “since the Yucatan Peninsula is an important stopover site for avoiding significant impacts have no scientific basis, since no one can
birds that cross the Gulf of Mexico during migration; it is necessary to predict a priori the direct or indirect effects of the projects with any
take into account the possible negative effects of the project for several degree of certainty. Predictions are based on mathematical models that
bird migration scenarios; that is, not only the migration of raptors of have to be verified by data collected using standardized methodologies.
medium and large size, but also the migratory pulses of passerine birds It is almost impossible to predict effects without observational data
that take place at overnight” (SEMARNAT, 2017a). obtained once projects are operational. In some cases, model predictions
Finally, according to the opinion of some experts who attended the claiming negligible probability of birds colliding with turbine rotors
public consultation for the Sinanché wind farm, one of the shortcomings have been proven totally erroneous, thus indicating the danger of
of the EIS is the fact that “the sites for sampling submitted by the project placing too much faith in mathematical models, however sophisticated
promoters are located only within the boundaries of the site in which it they may be (Abdulle and Fraser, 2018; Kuvlesky et al., 2007).
is proposed to develop the wind farm and in a vicinity no greater than Following the same line of reasoning, the EIS for the Progreso wind
5 km from the project area” (CEMDA, 2016, p. 36). In this way, the EIS in farm affirms that “the project will have little effect on biodiversity and
question disregards the recommendations of the POETCY (ecological that, by scaring animals away or rescuing them and relocating them, any
regulation criterion Number 65) that advises conducting studies of the effects will be further reduced” (Pontones and Ledesma, 2016b, p.
fauna in a radius of 50 km around the project area (POETCY, 2014, p. IV-43). Therefore, it claims “that diversity in the Regional Environ
21). The EIS also disregards the recommendations of SENER, which mental System will not be compromised or put at risk by the wind farm”
states that for birds “in general, a minimum radius of 10 km around the (Pontones and Ledesma, 2016b).
area of influence of the wind project should be considered in order to However, the EIS overlooks the fact that there are no proven methods
assess possible interactions with the bird and bat populations within the for keeping animals away without causing an impact at the site. Also,
broader environmental system” (SENER, 2016). It should be noted that even if animals could be caught and “rescued”, there is no indication as
none of the wind farm projects in the Yucatan Peninsula has carried out to where they could be released. Any release site would need to be
monitoring in an area of 50 km around the project area. Some of the evaluated prior to such an endeavor in order to assess if the habitat is
disparities in all these criteria and animal monitoring are resumed in suitable. Moreover, no monitoring of these animals is proposed and it
Table 4. would therefore be impossible to evaluate the success of such a program.
In the case of birds, the suggested relocation of nest sites is patently
5.4. Ineffectiveness of the regulatory norms applicable to the territory and absurd and displays a complete lack of understanding of animal
repetition of ecological slogans behavior.
In the same document, the authors assert that “the effects of the
The following is another example of how the EIA fails to comply with construction and operation of wind farms on terrestrial fauna can be
environmental regulations. In relation to this case, we propose to negligible, since human activity is minimal during the operation of the
compare both the arguments from the company and from the authority farm, so the project will not have an effect on the abundance of different
with the official regulations. One of the foremost concerns raised by civil fauna” (Pontones and Ledesma, 2016b, p. V-12). According to the au
society is the impact that the excavation of foundations will have on the thors, “post-construction studies show that fauna returns to the area”
8
Table 4
Project characteristics, definition of the influence area and monitoring definitions: birds, felids and bats.
Project Number of towers Declared surface Direct influence Bird monitoring Felid Bat monitoring
(ha) areaa monitoring
Dzilam Bravo 36 1314.55 1 km Two weeks, outside the migration Not mentioned One night only
period
Progreso 36 48.3 100 m Not specified Not mentioned Not specified
Sinanché 72 3222 500 m Two periods in one year Not specified 19 days
Tizimín 41 1725 300 m One year Not mentioned One year, but not specified
Chicxulub 20 1156.68 Not specified One year Not mentioned One yearb
a
The geographical area within which a direct environmental impact is defined.
b
112 h with mist nets and 9 h with ultrasonic records.
(Pontones and Ledesma, 2016b). Although it is true that some case corresponding resolution” (SEMARNAT, 2017b, p. 48).
studies in other countries show that there were no measurable effects However, the application of these measures cannot be verified
post-construction, others show that there were significant impacts on publicly because this information remains reserved to the SEMARNAT
certain species. Therefore, it is impossible (and unethical) to claim that and the company itself, and because there is no independent commission
studies carried out at one site can be applied to another. This is espe that monitors the application of said measures during the construction
cially true in areas with important migratory movements such as the and operation of the projects. Regarding this void, and in an effort to
Yucatan Peninsula. Also, most post-construction studies to date refer to guarantee the neutrality of the process, the SEMARNAT states that “to
sites in temperate zones, and virtually no studies have been conducted at comply with the evaluation of the execution and operation of the project
tropical sites. in the terms laid down, and to carry out evaluations of the effectiveness
Finally, it seems that no official designation (e.g. IBA’s, RHP’s, and efficiency of the Environmental Management Program prior to the
RMP’s) are important enough to prevent the installation of wind farms presentation of Annual Reports, an Environmental Supervisor should be
in ecologically sensitive areas or to ensure their regulation. In the official appointed to act in a manner autonomous to the promoter”, that is to the
ruling, the SEMARNAT remarks that “none of these designations include company that owns the park (SEMARNAT, 2017b, p. 59). However, it is
a plan or program that contravenes, limits, or prohibits the development not established how this autonomy will be guaranteed since the Envi
of such projects” (SEMARNAT, 2017b, p. 20). In the absence of such ronmental Supervisor is appointed and paid for by the company and is
programs, the ruling emphasizes the importance of implementing not publicly accountable, being therefore both judge and jury in the
measures aimed at minimizing the impact of the project (SEMARNAT, process.
2017b). However, given that the pre-construction studies are so poorly Moreover, there is another problem that makes it unlikely that
designed, evaluating the true impact (or the success of mitigation and measures dictated in the ruling will actually be applied. In most cases, a
compensation programs) will be impossible. project promoter embarks on the EIS procedure with the intention of
selling the project on to a third party. This new agent then redesigns the
5.5. Lack of consistency in EIA rulings emitted by environmental project (choosing, for example, the technology to be used). Although the
authorities and the impossibility of monitoring long-term impacts new owner submits an update to the environmental authority, the
SEMARNAT, this is a post-opinion procedure that is not disclosed to the
As mentioned previously, the SEMARNAT must publish their rulings public. That is, the authorizing body allows changes that have no public
after reviewing the EIS for each project as well as considering the verification mechanisms. For that reason, some promoters and author
various comments from authorities, social organizations, or individual ities are fully cognizant of the fact that no project is, in fact, built ac
citizens. These rulings attest to the procedural nature of the EIA. In most cording to the provisions in the EIS once it has been approved. For
cases, in view of the inconsistencies pointed out by different actors, the example, according to the EIS for the Dzilam wind farm, the foundations
SEMARNAT simply requests that the company presents additional for the turbines were to be buried underground (Copremia, 2013, p.
information. IV-24). However, for reasons that have not been made public,
For example, the EIS for the Sinanché wind farm does not include an
evaluation of the impacts that the construction of a network of roads
included within the project itself could have on ecosystems. For civil
society groups and experts, this was an important omission that, on its
own, should have justified denying the permit, since construction of
roads is one of the principal causes of habitat disturbance and frag
mentation (CEMDA, 2016). In response to the criticism that bird
monitoring sites were limited to the project area, and that the EIS
claimed there were no migratory routes detected (despite being on a
major migratory highway), the SEMARNAT simply asked the company
to carry out “continuous sampling” and to respect “as far as possible the
areas with higher breeding activity or those with better preserved
vegetation cover” (SEMARNAT, 2017a). In other words, weaknesses
pointed out in the study were blatantly ignored in the ruling.
Despite their serious shortcomings, to date, no EIA for wind projects
in Yucatan has been rejected by the SEMARNAT. In general, the SEM
ARNAT approves these projects on condition that the company un
dertakes future technical studies, applies specific programs, and
presents annual reports. The SEMARNAT assumes that “even though
there will be environmental impacts caused by the project, these will be
minimized, mitigated, prevented, or compensated by applying a series of Fig. 3. The semi-hidden foundations for the wind towers in the Dzilam Bravo
measures proposed by the promoter as well as those indicated in the wind farm.
9
semi-hidden foundations were built, heightening the visual impact on Faced with their inability to assess the real impacts of wind power,
the landscape (Fig. 3). consultants and companies resort to using pure rhetoric, minimizing the
Since 2017, the SEMARNAT has asked companies to carry out a se impacts without presenting any scientific evidence to back up their
ries of regional studies for three groups of fauna: birds, bats and felids.12 claims. Even the most complete studies are based on models that can
These conditions are based on the recognition that the region “has only be verified through experiments. Added to the limits or deficiencies
considerable potential for the establishment of renewable energy pro of the rational planning model, is the negligence of public authorities
jects (mainly wind and solar) and that there are already several autho that have failed to build the technical and scientific capacities to
rized projects” (SEMARNAT, 2017b, p. 60). The SEMARNAT stipulates improve traditional environmental impact procedures.
that companies “must carry out regional analyses of bird and bat pop While the Mexican government has shown a political interest in
ulations, either individually or in coordination with other authorized committing to an energy transition, there has not been a corresponding
wind and solar farms on the Yucatan Peninsula.” (SEMARNAT, 2017b, p. interest in aligning or harmonizing the laws that regulate the imple
61). According to the SEMARNAT, “the goals of the aforementioned mentation of such projects. The process adheres to a superficial idea of
analyses are to understand the migratory routes of birds and bats (sic)13 sustainability, one that assumes that renewable energy projects are
that cross the Yucatan Peninsula as well as to understand their diurnal somehow intrinsically “ecological”. In opposition to this assumption,
and nocturnal biological activities.” In addition, the study “should this paper aims to show that sustainability must be built with clear
include an inventory of all the species present in said Peninsula, as well norms and rules for measuring impacts, and policies that respect local
as establishing the spatial distribution of their habitats, and how they territorial planning and use. Furthermore, it should include decision-
use them”. They further stipulate that “the migration routes identified be making strategies that allow wind planning and nature conservation
monitored for at least five years in order to estimate species densities to coincide. With this paper, we have demonstrated that EIA in Mexico
and/or numbers”. Additionally, “the results of these analyses should be remains an extremely poor instrument for wind project development.
compared with those obtained through monitoring each individual site The transition to renewable energy places extra demands on public
in order to determine the collision risk index that those wind or solar authorities to update the mechanisms and instruments for its regulation
farms have on the peninsula” (SEMARNAT, 2017b, p. 62).14 as well as improving public participation. However, so far, the political
In our opinion, these recommendations are an acknowledgment by and administrative structure in Mexico has hampered the transformative
the SEMARNAT that EIS documents do not comply with the law nor do potential of the transition because the mechanisms for public partici
they guarantee protection of the environment. With these recommen pation are weak and environmental regulations are an afterthought.
dations, the SEMARNAT transfers the responsibilities for environmental As we have shown, the most important criteria currently applied for
protection to the private companies without generating the technical approving projects are technical and financial, not ecological or social.
conditions to correct the deficiencies of the EIA or elaborating mecha In that context, it is necessary to avoid purely engineering approaches to
nisms such as the SEA. using renewable sources of energy. It is also necessary to recast the way
In response to the SEMARNAT’s demand for a regional analysis, a we think about renewables by using mechanisms that do not separate
dozen renewable energy companies formed the “Asociación Peninsular energy from the environment, either technically or administratively. In
de Energías Renovables (“Peninsular Association of Renewable En this regard, the rational vision of planning does not guarantee
ergies”) or APER (Escalante, 2018). This association is supposed to co sustainability.
ordinate the continuous monitoring activities and share the elevated We believe that a different paradigm should be followed when
costs that are involved, including radar techniques. In this way, the implementing a series of large-scale projects in ecologically sensitive
SEMARNAT essentially transfers its responsibilities to the companies regions such as the Yucatan. Indeed, such a paradigm has already been
although, as previously mentioned, there is no independent body to enshrined in Mexico’s Law of Energy Transition (LTE, 2015), which
verify the application of these measures. Moreover, since there are no proposes a Strategic Environmental Assessment (SEA) for such regions.
standardized monitoring guidelines, and comparing data from different However, there is no good precedent for a SEA in Mexico, and the federal
project sites is not possible, an integral impact assessment is exceedingly authorities lack the expertise that has been developed in other countries.
difficult. It should also be pointed out that APER is also used to green SEA may be a unique opportunity to develop public policies with
wash its public image and exert political pressure on local authorities (El emphasis on environmental priorities and public participation, and to
Economista, 2019). establish the local vision as the basis for regional development plans, in
harmony with the country’s policies and the global commitment to fight
6. Conclusion and policy implications Climate Change.
In this discussion, we have shown that, given the way in which EIA CRediT authorship contribution statement
processes are carried out, it is very difficult to predict the actual impacts
of wind power on the coastal ecosystems of Yucatan, since the necessary Ezequiel Zárate-Toledo: Conceptualization, Methodology, Formal
baseline information on their previous status is not available. analysis, Investigation, Resources, Writing – original draft, Writing –
Evaluations are made even more difficult by the lack of standardi review & editing. Paul Wood: Conceptualization, Formal analysis,
zation of monitoring methods and the existence of a series of legal Investigation, Resources, Validation, Writing – review & editing.
loopholes in how the total area affected is defined, including a lack of Rodrigo Patiño: Conceptualization, Formal analysis, Investigation,
guidance on how to define regional environmental systems. For Resources, Writing – review & editing.
example, there is zero assessment of nocturnal bird migration, which
represents one of the most serious potential impacts. In addition to these Declaration of competing interest
serious omissions, ecological management plans are weak or unrealistic
and there is no assessment of the limits to wind development in this The authors declare that they have no known competing financial
region. interests or personal relationships that could have appeared to influence
the work reported in this paper.
12
Jaguar is a representative felid in Yucatan (Roques et al., 2016). Acknowledgments
13
Bats in Yucatan are not migratory species.
14
The same conditions are repeated in different resolutions for wind farms in EZT thanks LANRESC-UNAM for the interest in initiating this paper.
Yucatan. The authors thank the reviewers of the manuscript for their comments to
10
improve this paper. El Economista, 2019. Inversión de 4,500 millones de dólares. Yucatán apuesta por
energías renovables: autoridades locales y la APER desarrollarán una agenda de
trabajo para consolidar proyectos de energía eólica y fotovoltaica. El Economista, 3/
Appendices I, II and III. Supplementary data 5/2019. https://www.eleconomista.com.mx/estados/Yucatan-apuesta-por-ener
gias-renovables-20190305-0006.html. (Accessed 13 April 2021).
Supplementary data to this article can be found online at https://doi. Escalante, H., 2018. A punto de “girar” parque eólico de Dzilam. Desde el Balcón, 9/25/
2018. https://www.desdeelbalcon.com/a-punto-de-girar-parque-eolico-de-dzilam/.
org/10.1016/j.enpol.2021.112525. (Accessed 13 April 2021).
Euán-Ávila, J.I., 2014. In: García de Fuentes, A., Liceaga Correa, M.A., Munguía Gil, A.
References (Eds.), La costa del estado de Yucatán, un espacio de reflexión sobre la relación
sociedad-naturaleza, en el contexto de su ordenamiento ecológico territorial, vol. I.
Plaza y Valdéz, Mexico.
Abdulle, S.A., Fraser, K.C., 2018. Does wind speed and direction influence timing and Fortin, M.J., 2009. L’Évaluation environnementale de grands projets industriels :
route of a trans-hemispheric migratory songbird (purple martin) at a migration potentialités et limites pour la gouvernance territoriale. VertigO 9 (1). http://vert
barrier? Anim. Migrat. 5 (1), 49–58. https://doi.org/10.1515/ami-2018-0005. igo.revues.org/8505.
Articulación Yucatán, 2018. Compendio de opiniones técnicas respecto a la revisión de la GeoComunes, 2019. Geovisualizador de la Península de Yucatán. http://geocomunes.
MIA Regional del Proyecto: “PARQUE EÓLICO CHICXULUB” que pretende ubicarse org/Visualizadores/PeninsulaYucatan/. (Accessed 13 April 2021).
en los municipios de Motul, Ixil y Progreso, Yucatán; y promovido por la empresa, Hooper, T., Austen, M.C., Beaumont, N., Heptonstall, P., Holland, R.A., Ketsopoulou, I.,
Eólica del Mayab, S.A.P.I. DE C.V. Emitidas en el marco de la Consulta Pública de la Taylor, G., Watson, J., Winskel, M., 2018. Do energy scenarios pay sufficient
SEMARNAT. https://articulacionyucatan.files.wordpress.com/2018/10/co attention to the environment? Lessons from the UK to support improved policy
mentarios-colectivos_-eocc81lico-de-chicxulub.pdf. (Accessed 13 April 2021). outcomes. Energy Pol. 115, 397–408. https://doi.org/10.1016/j.enpol.2018.01.028.
Atienza, J.C., Martín Fierro, I., Infante, O., Valls, J., Domínguez, J., 2011. Directrices Howe, C., Boyer, D., Barrera, E., 2015. Los márgenes del Estado al viento: autonomía y
para la evaluación del impacto de los parques eólicos en aves y murciélagos (versión desarrollo de energías renovables en el sur de México. J. Lat. Am. Caribb. Anthropol.
3.0). SEO/BirdLife, Madrid. 20 (2), 1–23.
Bayly, N.J., Rosenberg, K.V., Easton, W.E., Gómez, C., Carlisle, J., Ewert, D.N., Drake, A., Ingesa, S.A.C.V., 2019. Manifestación de Impacto Ambiental Modalidad Regional
Goodrich, L., 2018. Major stopover regions and migratory bottleneck for Nearctic- Ampliación del Parque Eólico Tizimín. https://articulacionyucatan.files.wordpress.
Neotropical landbird within the Neotropics: a review. Bird. Conserv. Int. 28, 1–26. com/2019/10/31yu2019e0031.pdf. (Accessed 13 April 2021).
Bojórquez-Tapia, L.A., Garcı́a, O., 1998. An approach for evaluating EIAS— deficiencies Inecol, 2018. Manifestación de Impacto Ambiental Regional, para la construcción y
of EIA in Mexico. Environ. Impact Assess. Rev. 18 (3), 217–240. operación de Proyecto Parque Eólico Chicxulub a ubicarse en los municipios Motul.
Bresciani, C., 2019. Énergies renovelables en Amérique latine: les apports de Ixil y Progreso en el estado de Yucatán, presentado por la empresa Eólica del Mayab.
l’anthropologie. Lectures anthropologiques. http://lecturesanthropologiques.fr/l S.A.P.I. de C.V. https://articulacionyucatan.files.wordpress.com/2018/08/proyecto
odel/lecturesanthropologiques/index.php?id=670&file=1. (Accessed 5 May 2020). -parque-ec3b3lico-chicxulub.pdf. (Accessed 13 April 2022).
Callon, M., Lascoumes, P., Barthe, Y., 2009. Acting in an Uncertain World. An Essay on Jalava, K., Pasanen, S., Saalasti, M., Kuitunen, M., 2010. Quality of environmental
Technical Democracy. The MIT Press, London. impact assessment: Finnish EISs and the opinions of EIA professionals. Impact Assess.
Cam, S.A.C.V., 2017. Manifestación de Impacto Ambiental Regional para el proyecto Proj. Apprais. 28 (1), 15–27. https://doi.org/10.3152/146155110X488826.
Parque Eólico Progreso a ubicarse en el municipio de Progreso. Yucatán, presentado Kuvlesky Jr., W.P., Brennan, L.A., Morrison, M.L., Boydston, K.K., Ballard, B.M.,
por la empresa Energía Renovable de la Península. S.A.P.I. de C.V. https://articula Bryant, F.C., 2007. Wind energy development and wildlife conservation: challenges
cionyucatan.files.wordpress.com/2018/05/23_parque-ec3b3lico-progreso.pdf. and opportunities. J. Wildl. Manag. 71 (8), 2487–2498. https://doi.org/10.2193/
(Accessed 13 April 2021). 2007-248.
Cashmore, M., Richardson, T., Hilding-Ryedvik, T., Emmelin, L., 2010. Evaluating the Larsen, S.V., Hansen, A.M., Nielsen, H.N., 2018. The role of EIA and weak assessments of
effectiveness of impact assessment instruments : Theorising the nature and social impacts in conflicts over implementation of renewable energy policies,.
implications of their political constitution. Environ. Impact Assess. Rev. 30, Energy Pol. 115, 43–53. https://doi.org/10.1016/j.enpol.2018.01.002.
371–379. https://doi.org/10.1016/j.eiar.2010.01.004. Ledec, G.C., Rapp, K.W., Aiello, R.G., 2011. Greening the Wind : Environmental and
CEFAS (Centre for Environment Fisheries and Aquaculture Science), 2010. Strategic Social Considerations for Wind Power Development. A World Bank Study. World
review of offshore wind farm monitoring data associated with FEPA license Bank, Washington, DC. http://documents.worldbank.org/curated/en/23985146808
conditions. https://tethys.pnnl.gov/sites/default/files/publications/Cefas-2010.pdf. 9382658/Greening-the-wind-environmental-and-social-considerations-for-wind-po
(Accessed 13 April 2021). wer-development.
CEMDA, 2016. Cuestionario Consulta Pública del proyecto denominado: parque Eólico LGEEPA, 2015. Ley General del Equilibrio Ecológico y la Protección al Ambiente.
Sinanché fase I y Fase II. https://articulacionyucatan.files.wordpress.com/2020/05 http://biblioteca.semarnat.gob.mx/janium/Documentos/Ciga/agenda/DOFsr/148.
/final_comentario-colectivo_-mia-sinanchecc81.pdf. (Accessed 13 April 2021). pdf. (Accessed 13 April 2021).
CEMDA, 2013. Cuestionario de Consulta Pública del proyecto denominado: parque LIE, 2021. Ley de la Industria eléctrica. http://www.diputados.gob.mx/LeyesBiblio/pd
Eólico de Dzilam Bravo. https://articulacionyucatan.files.wordpress.com/2020/05/ f/LIElec_090321.pdf. (Accessed 13 April 2021).
comentarios-parque-eolico-dzilam-bravo_-final_2.pdf. (Accessed 13 April 2021). Limoges, C., Doray, P., Henrichon, P., Cimon, M., Veilleux, D., 1993. L’état et les
Colvin, R.M., Witt, G.B., Lacey, J., 2016. How wind became a four-letter word: lessons for préoccupations des citoyens relatives aux incidences du changement technologique.
community engagement from a wind energy conflict in King Island, Australia. Conseil Sci. Technol. (Québec. Gouvernement du Québec, Sainte-Foy).
Energy Pol. 98, 483–494. https://doi.org/10.1016/j.enpol.2016.09.022. LTE, 2015. Ley de Transición energética. http://www.diputados.gob.mx/LeyesBiblio/pd
Conabio, 2021. Áreas de Importancia para la Conservación de Aves. http://avesmx. f/LTE.pdf. (Accessed 13 April 2021).
conabio.gob.mx/AICA.html. (Accessed 13 April 2021). Moreno-Gómez, M., Martínez-Salvador, C., Moulahoum, A.W., Liedl, R., Stefan, C.,
Consultores en Ecosistemas, S.C., 2016. Manifestación de Impacto Ambiental Regional Pacheco, J., 2019. First steps into an integral karst aquifier vulnerability approach
para la construcción y operación de un Parque Eólico a ubicarse en el municipio de (IKAV). Intrinsic groundwater vulnerability analysis of the Yucatan karst, Mexico.
Dzilam de Bravo. Yucatán, presentado por la empresa Central Eólica de la Península. Water 11, 1610.
S.A.P.I. de C.V. https://articulacionyucatan.files.wordpress.com/2018/05/20_centra Nadaï, A., 2007. “Planning’’, “siting’’ and the local acceptance of wind power: some
l-eolica-de-la-peninsula.pdf. (Accessed 13 April 2021). lessons from the French case. Energy Pol. 35, 2715–2726.
Copremia, S.C.P., 2013. Manifestación de impacto ambiental modalidad particular Ortiz, G., Climent-Gil, E., 2020. A transdisciplinary framework for environmental impact
parque eólico Dzilam Bravo, ubicado en el municipio de Dzilam Bravo, Yucatán. htt assessment: opportunities and resistances among practitioners in Spain. Environ.
ps://articulacionyucatan.files.wordpress.com/2018/05/3_parque-ec3b3lico-dzilam- Impact Assess. Rev. 81 (106339) https://doi.org/10.1016/j.eiar.2019.106339.
bravo.pdf. (Accessed 13 April 2021). Patiño, R., 2018. La Evaluación Ambiental Estratégica para la Transición Energética en
Côté, G., Waaub, J.P., Mareschal, B., 2017. L’évaluation d’impact environnemental et Yucatán: propuesta Técnica. https://articulacionyucatan.files.wordpress.com/2018/
social en péril. VertigO 17 (3). http://journals.openedition.org/vertigo/18813. 10/propuesta-tecc81cnica-eae.pdf. (Accessed 13 April 2021).
Côté, G., Waaub, J.P., 2012. Mécanismes de participation publique dans les évaluations POETCY, 2014. Decreto 160/2014 por el que se expide el Programa de Ordenamiento
environnementales stratégiques. Rap. Final Remis Comité Environ. Strat. gaz de Ecológico del Territorio Costero del Estado de Yucatán. http://bitacoraorden
Schiste. http://archives.bape.gouv.qc.ca/sections/mandats/gaz_de_schiste-enje amiento.yucatan.gob.mx/archivos/DECRETO_160_2014_POETCY.pdf. (Accessed 13
ux/documents/PR3.3.1.pdf. (Accessed 13 April 2021). April 2021).
Deppe, J.L., Ward, M.P., Bolus, R.T., Diehl, R.H., Celis-Murillo, A., Zenzal, T.J., Moore, F. POETCY, 2007. Decreto por el que se formula y expide el Programa de Ordenamiento
R., Benson, T.J., Smolinsky, J.A., Schofield, L.N., Enstrom, D.A., Paxton, E.H., Ecológico del Territorio Costero del Estado de Yucatán. http://bitacoraordenamie
Bohrer, G., Beveroth, T.A., Raim, A., Obringer, R.L., Delaney, D., Cochran, W.W., nto.yucatan.gob.mx/archivos/200708031573.pdf. (Accessed 13 April 2021).
2015. Fat, weather, and date affect migratory songbirds’ departure decisions, routes, Pontones, Ledesma, S.C., 2016a. Manifestación de Impacto Ambiental Regional para el
and time it takes to cross the Gulf of Mexico. Proc. Natl. Acad. Sci. U. S. A. 112 (46), Proyecto “Parque Eólico Tizimín” a ubicarse en el municipio de Tizimñin, Estado de
E6331–E6338. https://doi.org/10.1073/pnas.1503381112. Yucatán. https://articulacionyucatan.files.wordpress.com/2018/05/16_parque-ec
Devine-Wright, P., Wiersma, B., 2020. Understanding community acceptance of a 3b3lico-tizimin.pdf. (Accessed 13 April 2021).
potential offshore wind energy project in different locations: an island-based analysis Pontones, Ledesma, S.C., 2016b. Manifestación de Impacto Ambiental Regional para el
of ‘place-technology fit’. Energy Pol. 137, 111086. https://doi.org/10.1016/j. Proyecto “Parque Eólico Sinanché Fase I y Fase II”, a ubicarse en los municipios de
enpol.2019.111086. Sinanché, Yobaín y Telchac Pueblo, Estado de Yucatán, presentado por la empresa
Durán García, R., Méndez González, M. (Eds.), 2010. Biodiversidad y Desarrollo Humano Fuerza y Energía Limpia de Yucatán, S. de R.L. de C.V., y Fuerza y Energía Limpia de
en Yucatán. CICY, PPD-FMAM, CONABIO, SEDUMA, Mérida. https://www.cicy. Kukulkán. S. A de C. V. https://articulacionyucatan.files.wordpress.com/2018/05/
mx/sitios/biodiversidad-y-desarrollo-humano-en-yucatan. (Accessed 5 May 2020). 13_parque-ec3b3lico-sinanche-fase-i-y-fase-ii.pdf. (Accessed 13 April 2021).
11
Ramsar, 2021. https://www.ramsar.org/. (Accessed 13 April 2021). SEMARNAT, 2014. Resolutivo en materia ambiental, Proyecto Parque Eólico de Dzilam
Roques, S., Sollman, E., Jácomo, A., Tôrres, N., Silveira, L., Chávez, C., Keller, C., Mello Bravo, presentado por la empresa Vive Energía SAPI de CV, con pretendida
do Prado, D., Carignano Torres, P., Jorge dos Santos, J., Bernardes Garcia da Luz, X., ubicación en el municipio de Dzilam de Bravo, en el estado de Yucatán. Oficio No.
Magnusson, W.E., Godoy, J.A., Ceballos, G., Palomares, F., 2016. Effects of habitat 76.4/UGA-258/000773. https://articulacionyucatan.files.wordpress.com/2018/05/
deterioration on the population genetics and conservation of the jaguar. Conserv. 3_parque-ec3b3lico-dzilam-bravo1.pdf. (Accessed 13 April 2021).
Genet. 17, 125–139. SENER, 2016. La Evaluación Ambiental y Social Estratégica para el desarrollo eólico en
Richardson, T., 2005. Environmental assessment and planning theory: four short stories el sur del Istmo de Tehuantepec. https://www.gob.mx/cms/uploads/attachment/fi
about power, multiple rationality, and ethic. Impact Assess. Rev. 25, 341–365. le/136647/18439_EASE_E_lico_Tehuantepec_Resumen_ejecutivo_espa_ol.pdf.
https://doi.org/10.1016/j.eiar.2004.09.006. (Accessed 13 April 2021).
SCGI, S.A.C.V., 2017. Manifestación de Impacto Ambiental Línea de Transmisión Parque Serrano-Rodríguez, A., Escalona-Segura, G., Iñigo Elias, E.E., Serrano Rodríguez, A.,
Eólico Tizimín. Subestación Tizimín. https://articulacionyucatan.files.wordpress.co Uriostegui, J.M., Montes de Oca Aguilar, A.C., 2018. Potential distribution and
m/2018/05/24_construccic3b3n-montaje-e-instalacic3b3n-de-lc3adnea-de-trasmisi climatic niche of seven species of Campylorynchus (Aves, Troglodytae): conservation
c3b3n-elc3a9ctrica-115-kv-denominada-parque-ec3b3lico-tizimin.pdf. (Accessed 13 implications for C. yucatanicus. Wilson J. Ornithol. 130 (1), 13–22. https://doi.org/
April 2021). 10.1676/16-101.1.
Schumacher, K., 2019. Approval procedures for large-scale renewable energy Smart, D.E., Stojanovic, T.A., Warren, C.R., 2014. Is EIA part of the wind power planning
installations: comparison of national legal frameworks in Japan, New Zealand, the problem? Environ. Impact Assess. Rev. 49, 13–23. https://doi.org/10.1016/j.
EU and the US. Energy Pol. 129, 139–152. https://doi.org/10.1016/j. eiar.2014.05.004.
enpol.2019.02.013. Smith, A.L., Salgado Ortíz, J., Robertson, R.J., 2001. Distribution patterns of migrant and
Schwertner Hoffmann, A., Henriques de Carvalhob, G., Cardoso, R.A.F., 2019. resident birds in successional forests of the Yucatan Peninsula, Mexico. Biotropica 33
Environmental licensing challenges for the implementation of photovoltaic solar (1), 153–170. https://doi.org/10.1111/j.1744-7429.2001.tb00165.x.
energy projects in Brazil. Energy Pol. 132, 1143–1154. https://doi.org/10.1016/j. Vaissière, A.C., Levrel, H., Pioch, S., Carlier, A., 2014. Biodiversity offsets for offshore
enpol.2019.07.002. wind farm projects: the current situation in Europe. Marine Policy 48. https://doi.
SEMARNAT, 2017a. Resolutivo en materia ambiental, "Proyecto Parque Eólico Sinanche, org/10.1016/j.marpol.2014.03.023, 172-183.
Fase I y Fase 11", presentada por las empresas Fuerza y Energía Limpia de Yucatán, Warren, C., Lumsden, C., O’Dowd, S., Birnie, R., 2005. “Green on green” : public
S. de R.L. de C.V., y Fuerza y Energía Limpia de Kukulkán, S. A de C.V. Con perceptions of wind power in scotland and Ireland. J. Environ. Plann. Manag. 48 (6),
pretendida ubicación en los municipios de Sinanché, Yobaín y Telchac Pueblo en el 853–875.
estado de Yucatán. Oficio No. SGPA/DGIRA/DG, 00648. https://articulacionyucatan Wolsink, M., 2007. Planning of renewables schemes: deliberative and fair decision-
.files.wordpress.com/2018/05/13_parque-ec3b3lico-sinanche-fase-i-y-fase-ii1.pdf. making on landscape issues instead of reproachful accusations of non-cooperation.
(Accessed 13 April 2021). Energy Pol. 35 (5), 2692–2704.
SEMARNAT, 2017b. Resolutivo en materia ambiental, “Proyecto Parque Eólico Zárate Toledo, E., Fraga, J., 2016. La política eólica mexicana: controversias sociales y
Progreso”, presentada por la empresa Energía Renovable de la Península, S.A.P.I. DE ambientales debido a su implantación territorial. Estudios de caso en Oaxaca y
C.V. Con pretendida ubicación en el municipio de Progreso, Yucatán. Oficio No. Yucatán. Trace 69, 65–95.
SGPA/DGIRA/DG/2862. https://articulacionyucatan.files.wordpress.com/2018/0 Zárate Toledo, E., Patiño, R., Fraga, J., 2019. Justice, social exclusion and indigenous
5/23_parque-ec3b3lico-progreso1.pdf. (Accessed 13 April 2021). opposition: a case study of wind energy evelopment on the Isthmus of Tehuantepec,
Mexico. Energy Resear. Soc. Sci. 54, 1–11.
12

Articulo 1. Equipo1 Se

Uploaded by

Copyright:

Available Formats

Articulo 1. Equipo1 Se

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Articulo 1. Equipo1 Se

Uploaded by

Copyright:

Available Formats

Energy Policy 158 (2021) 112525

Contents lists available at ScienceDirect

In search of wind farm sustainability on the Yucatan coast: Deficiencies and

3.2. Application of the EIA in a contested regulatory framework

transparency is recognized in the monitoring of impacts by companies

measures to improve the quality of impact studies, the authorities’

You might also like