The Basque environmental movement has been calling for decades for a renewable energy plan to ensure public control of the energy system, to reduce energy consumption, to increase efficiency, to decentralise and, with the leadership of local institutions, to ensure public control of the energy system. To our surprise, late and badly, the initial document of the Basque Sector Regional Plan for Renewable Energy (PTS) has now been made public.

The aim of this article is to explain why we are against this PTS who have traditionally opted for renewables. We take this opportunity to pass on our reasons to the groups and public bodies concerned so that they can invoke the SPEE-PTS.

1. In our Autonomous Community, which triples the density of the European population (302 inhabitants/km²), 38% of the contribution of energy-intensive production to gross domestic product is due to industry and construction (0.8% for the primary sector). The strong increase in the metropolization and colmatation process foreseen in the SPEE-PTS would mean the loss of the sense of life, cultural and landscape of the mountains and valleys.

2. The Conservation PTS is not compatible with protected natural spaces or protected species. In particular, Law 9/2021, of November 25, on Conservation of Natural Heritage and Foral Orders on Management Plans for Necrophagous Birds.

3. This PTS is incompatible with Decree 128/2019 of 30 July, which definitively approves the Guidelines for the Management of the Territory of the Basque Country. This decree, which includes a new view of the landscape, states that “in outstanding landscapes as well as in everyday landscapes with organizational needs, heritage (cultural and natural) is a resource to protect and, in this sense, its sustainable management is fundamental”. The prioritisation of the PEEB-PTS over the Partial Territorial Plans has left the latter bankrupt.

4th. The US PTS is incompatible with food sovereignty, with the rural environment and with the Agroforestry PTS, since the only soils that are excluded from the occupation are those declared special value (own).

5. In the name of the so-called “energy transition” it is intended to sacrifice the most valuable, the least scarce and the non-renewable resource: the territory. The development of this PTS will lead to a serious deterioration of environmental indicators associated with soil artificialization.

6. The only “exempt spaces” in the PERI are the protected areas in the Natura 2000 network and the garden areas close to each urban centre. In the rest of the cases, the construction of infrastructure is made possible and the corrective function to be established by territorial planning is renounced.

7. This PTS does not comply with Law 9/2021 as regards “green infrastructures” and ecological corridors. As stated in the law, these elements “with the aim of improving coherence and ecological connectivity” will play a priority role, among others, mountain areas, “whether protected or not”.

8. The landscape guidelines contained in this PTS disregard the centrality of the landscape in the construction of our identity as a symbolic object possessed by one of the greatest capacities to build a sense of identity. Our popular character rooted in mountaineering has not been evaluated or respected.

9. The climate emergency does not justify nor should it prevent or hinder biodiversity loss. Measures such as public control of energy not covered by this PTS would be much more effective in not overcoming the capacity of the territory to assume biodiversity.

10. The mandatory Strategic Environmental Assessment of this PTS includes only generation infrastructures, without forecasting energy access or evaluation lines. This has distorted the scope and objectives of environmental assessment.

11. In this PTS, all energy demand data scenarios plan to maintain energy expenditure, although the Energy PTS recognizes the limits of electrification. Combined with energy savings, the necessary qualification and transformation of the productive fabric are the lines of action to be developed in an essential way.

12. The creation of a “culture of participation” that involves a greater number of social actors in the territorial planning processes runs counter to the rejection of the request to paralyse the procedure of processing this PTS until the formation of the new governments of the municipalities and the Foreign Ministers, having removed the right of participation from the local entities.

13. The transitional provision provides that the infrastructure in question is not affected by this PTS. In this sense, the case of projects that are developing outside the spaces proposed in the PTS is paradigmatic.

We therefore call for the suspension of all projects prior to the entry into force of the PTS.

Alberto Frias (President of the Earth), Vitoria

Aitziber Sarobe Egiguren (nature conservationist), Zarautz