For years, the chapter on fauna and flora in an environmental impact study has been the part of the document that almost no one discussed with figures in hand. It was inventoried, described, corrective measures were proposed, and it was concluded. The energy part of the project was defended with curves and balances; the biodiversity part, with adjectives.
This is coming to an end. And not due to a change in sensitivity, but due to a change in metrics.
What changes, exactly
The Regulation (EU) 2024/1991, relating to the restoration of nature, has been in force since 18 August 2024. It is a regulation, not a directive: it does not expect transposition. It establishes that the Union must have restoration measures in place for at least 20% of terrestrial and marine areas by 2030, and for all ecosystems that need it by 2050.
The Spanish calendar is already advancing: on 31 August 2026, MITECO submitted the draft national restoration plan to the European Commission, and on 25 September, the draft was made public on the MITECO website provisionally. The final version must be submitted before 1 September 2027.
For an engineer, the novelty is not the objective. It is that the objective comes accompanied by milestones, indicators and monitoring mechanisms. An objective with an indicator is an objective that someone will verify. And an indicator that someone will verify needs a defensible measurement method, not a convincing wording.
Three fronts that arrive sooner than they seem
Renewable promoters. The environmental monitoring programme ceases to be a report that is deposited and becomes a series that is compared. This is complemented by the draft royal decree for the protection of avifauna against energy infrastructures, in public information since 12 March 2025 and still not approved, which would replace RD 1432/2008 and generalise harmonised mortality sampling, automatic shutdown systems for wind turbines or on-site observers and scheduled shutdowns for bats. None of these measures is particularly expensive if designed from the outset of the park; all are if they come as an unforeseen condition with the plant already built.
Local administrations. The objectives of urban ecosystems apply to municipalities classified by Eurostat as DEGURBA 1 (cities) and DEGURBA 2 (towns and suburban areas). MITECO has made available a cartographic viewer with the delimitation of these areas. The first duty of a town council, now that the draft is public, is to know what delimitation it has assigned — because if it does not review it, the plan will set it for them.
Industry. The principle of no deterioration and habitat conditions do not only affect new installations: they affect expansions, water extractions and substantial modifications of authorisation. And, in parallel, biodiversity already appears in the due diligence and funding documents, where an environmental condition without a data series behind it is treated as an open risk.
Because this is measurement engineering, not drafting
This is where the conversation becomes truly technical, and where it is decided whether the piece holds up:
A count is not a rate. The specimens found in a survey are not the mortality. It is necessary to correct for search efficiency and for the permanence of corpses, and both factors depend on the terrain, the time of year, and who is searching. Without this correction, two identical plants can yield figures that cannot be compared with each other — nor with themselves from one year to the next.
The design of the sampling determines whether the number means anything. Frequency of visits, radius of survey, stratification by habitat units, seasonality. A poorly sized sampling does not yield a bad figure: it yields a figure that cannot be defended before anyone.
Without a baseline, there is no demonstration. A follow-up that starts the day the installation begins can describe a state, but cannot attribute an effect. The before/after comparison with control is what turns a data point into an argument.
The continuity of the series is the asset. Changing methods halfway destroys comparability. It is exactly the same lesson we have already learned with any energy baseline: the value is not this year's number, it is the series.
Four errors that we see repeating
After many environmental monitoring programmes, the pattern repeats:
- Design the follow-up to comply, not to decide. If the result cannot change any operational decision, the follow-up budget is an expense, not an investment.
- Publish indicators without a declared level of confidence. A figure without associated uncertainty is not a figure: it is an opinion with decimals.
- Not defining any activation threshold. If no one has written in advance what happens when the indicator goes off, the response will be improvised and late.
- Store the data in reports and not in a database. What is not consultable or aggregable is not a series; it is a file.
Four steps that can be started now
Now that the draft is public and we enter the observation phase of the European Commission, there is technical scope for anticipation. Four steps that do not require waiting for the final version of the plan:
- Locate yourself on the map. Delimitation of urban ecosystem if you are a municipality; proximity to SPA, regional recovery plans and priority areas if you are a developer or industry.
- Audit the series you already have. Applied method, temporal coverage, gaps, protocol changes. There are often more data than believed, poorly organised.
- Define baseline and activation thresholds before they are defined by a condition of the environmental impact statement.
- Put the data into a system. A consultable database, with method metadata, is worth more than ten impeccable reports.
Anticipation is not rushing: it is deciding in time
Biodiversity is following the same path that energy took: from qualitative topic to measurement discipline. And when a topic becomes a measure, it ceases to be a matter of opinion and becomes a matter of engineering. This is where an independent firm, with no product to sell, can tell you what the data says and not what you would like it to say.
If you are a DEGURBA 1 or 2 municipality and want to know what your urban ecosystem delimitation implies, or if you are a developer or industry and what you need is to review the design of your environmental monitoring programme before the next condition arrives, write to us.