Mike Levington (Vice Chairperson, SAPVIA) and Karen Jodas (Managing Director, Savannah Environmental and SAPVIA member) attended the first meeting of the Expert Reference Group (ERG) for the DEA’s Strategic Environmental Assessment (SEA) process on 27 March 2013 at the CSIR Campus in Pretoria.
The SEA process is a result of an instruction from Cabinet for DEA streamline the environmental permissioning process for the procurement of renewable energy from the private sector: this was one of the key issues identified to DOE and NT by SAPVIA, SAWEA and SASTELA in August 2012 as a major impediment to RE developers in readying projects for the REIPPP process.
In prior sessions with DEA and their consultants, CSIR, they have identified that RE development is expected to fit within the framework of the Strategic Infrastructure Project (SIP) process as articulated by the Presidential Infrastructure Coordination Committee (PICC), which seeks to identify economic corridors and then facilitate and remove barriers to economic development within them. In particular, our sector is inimically tied up in SIP8 (Green Energy in support of the South African economy), SIP9 (Electricity Generation to support socioeconomic development) and to an increasing extent SIP10 (Electricity Transmission and Distribution for all).
The intention is to identify preferred geographical areas within South Africa for solar PV and wind development where SEA’s will be performed to effectively give developers within those zones environmental pre-approval subject to specialist studies being performed to identify and show mitigation. These final zones will be denoted as solar (or wind) Renewable Energy Development Zones or REDZs, and the ambition from DEA is that full environmental approval processes will be reduced from the current 18-24 month experience down to 250 days. Projects outside of REDZs will need to follow a normal EIA process, but justification for the initiation of such a process will need to be given. In addition renewal of existing Environmental Approval will need to undergo the same scrutiny by DEA.
The expectation of this process is that CSIR will perform in-depth studies of these identified areas and final designated REDZs will be presented to Cabinet before the end of 2014 to be gazetted.
[restrictedarea]The workshop took ERG members through the scientific process followed by CSIR and CRSES to identify preferred zones for solar and wind development – it should be noted that CSP is specifically excluded from the SEA process as it is seemed to have too many specific issues to allow for a pre-approval process.
What specifically was raised from CSIR regarding the siting of solar REDZs were the following:
- The key parameters used to identify provinces that would host solar REDZ would be based on areas having highest solar isolation levels and concentration of projects. As such the WC, NC, FS, and NW Provinces were identified for further study.
- Unlike wind, which has a specific geographical territory, solar PV is seen as the most portable of the RE technologies and DEA has been advised by Eskom that it does not wish to undertake any major transmission build programmes to evacuate solar PV projects.
- As such, and this seemed to have been underpinned by the Project Steering Committee, the 2 parameters that have been used to further identify study areas for solar REDZs is grid connectivity and the ability to have the greatest socioeconomic uplift.
Concerns highlighted by the renewable energy associations present (SAPVIA, SAWEA and SESSA)
- General disappointment that this process should have been instituted before allowed such a proliferation of RE development throughout the country (SAPVIA and SAWEA).
- The establishment of REDZs could have the resultant effect of creating a class system throughout the sector and that projects being developed outside REDZs will be prejudiced either by government departments or financial institutions (SAPVIA).
- The expectation of the creation of real-estate bubbles in REDZ causing inflated prices being asked for within these areas (SAWEA).
- That commercial and industrial (self-use) IPPs outside of REDZs should not be subject to DEA’s justification process for EIA permissioning (SAPVIA)
- Concerns around treatment of projects that are partially outside REDZs borders – how will they be treated (SAWEA)?
- Lack of clarity over what exactly developers will receive by way of environmental permissions within REDZs; whether it will be consistent with the REIPPP requirements; whether lenders will find it a bankable document; and whether it will be consistent with the Equator Principles (important for many bi-lateral agencies) (SAPVIA).
- That weighting should be given to zones that reduce the requirement for major transmission build (SESSA).
There are expected to be further focus group sessions with CSIR during May-June 2013 when SAPVIA will be able to put forward other issues that need to be considered during the study process. The boundaries as shown are not set in stone, and a number of the study areas are expected to fall away in the process.
Whilst there are concerns regarding the viability of the REDZs process, it is clear that the process has been bought into politically and so far there is no alternative solution on the table. If SAPVIA members wish to propose other solutions to what is accepted by all to be an onerous process we are more than happy to hear them.
The presentations from the meeting can be viewed below:
National SEA GIS Methodology
EIA application mapping
National SEA major exclusion mapping
Preliminary solar study areas