Letter to the Ministry of Ecology and Environment: 3 proposals from CBCGDF to strengthen the biodiversity assessment of wind power projects
2021/12/22 17:14:00 本站

National Energy Administration recently issued a “Notice on the Second batch of National large-scale Wind Power Projects mainly focusing on the desert, Gobi, desert areas” (“Notice”), requiring the province as the main body to promote the development and construction of large key photovoltaic base projects and reported by December 15.

The Policy and Law Department of China Biodiversity Conservation and Green Development Foundation (CBCGDF) attached great importance to this. It is believed that the Notice was not guided by the idea of ecological civilization, but only focused on the “big work”, ignoring the biodiversity impact and risk prevention and control of the construction and operation of the project, which may adversely affect the carbon neutral work.

In response, the Policy and Law Department of CBCGDF wrote to the Ministry of Ecology and Environment, suggesting that the biodiversity impact assessment of wind power projects should be strengthened in three aspects. The following are the specific recommendations.

First, strictly implement veto system in wind power projects, making it environmental-friendly.

It is far from enough that the “Notice” includes mere one environmental protection requirement “not against the ecological red line”, which is a serious inconsistency with the requirements of environmental protection laws and regulations for construction projects. In particular, it should be noted that the initial national ecological protection red line does not cover all environmentally sensitive areas (e.g., the Tianjin Baguatan wetland, which CBCGDF has promoted for protection, has core ecological functions but is not included in the ecological protection red line.). And these areas such as "desert, Gobi, desert areas" are generally ecologically sensitive and fragile areas, once damaged, will certainly have an irreversible ecological impact on biodiversity and environment, hence a great impact on China's ecological security. Therefore, large wind power projects should be clearly required to strictly implement the environmental protection veto system, to effectively protect the important ecological functions of the region.

Secondly, biodiversity survey and assessment should be an important part of the environmental impact assessment of wind power projects.

“Opinions on Further Strengthening biodiversity protection” jointly issued by General Office of the CPC Central Committee and General Office of the State Council clearly required “assessment of impacts on biodiversity for large-scale engineering construction, resource development and utilization”, “taking the effectiveness of biodiversity protection as an important reference for comprehensive assessment and evaluation, accountability and off-office auditing of party and government leadership teams and leading cadres, and implementing lifelong accountability for those causing serious damage to the ecological environment and resources”, and proposed to “establish and improve the mechanism of biodiversity public interest litigation and strengthen the judicial guarantee of public participation in biodiversity protection”.

In the recently released guiding case No. 174 of the Supreme People's Court: China Biodiversity Conservation and Green Development Foundation (CBCGDF) filed a civil environmental public interest litigation (EPIL) against Yalong River Basin Hydropower Development Co. since the latter hasn’t made any biodiversity survey and assessment prior to its projects, resulting in the destruction of the habitat of Acer pentaphyllum Diels, a rare and critically endangered plant species. The legal cost of biodiversity damage was incurred by the defendant thereby. Therefore, it is suggested that for “desert, Gobi and desert areas”, especially the “offshore” areas which are widely concerned internationally, the biodiversity survey and assessment should be an important part of the environmental impact assessment of wind power projects.

Thirdly, intensify supervision of wind power projects.

Wind power projects generally occupy a large area, and will involve forest harvesting, vegetation excavation and other important issues on the ecological environment. It is suggested that Ministry of Ecology and Environment carry out regular or irregular inspections of the construction of wind power projects, as well as its ecological restoration at a later stage, and take biodiversity protection and ecological restoration as an important basis for project licensing and environmental protection acceptance.


Original Chinese article: https://m.weibo.cn/status/4716882018177004?wm=3333_2001&from=10BC293010&sourcetype=weixin