PV for biodiversity

As published in PV Magazine International September edition 2021.

Keeping track of the upcoming ecological sustainability regulations and recommendations and their impact on the solar industry is a real challenge. But simply relying on the belief that solar is ‘green’ enough because of the zero carbon electricity it produces is no longer enough. In her latest article, Everoze Partner Ragna Schmidt-Haupt investigates how the protection and restoration of biodiversity and ecosystems is likely to be of particular focus for solar PV.

PV’s contribution to a cleaner future can go well beyond generating emissions-free energy, but maximizing the opportunity is not always straightforward. Ragna Schmidt-Haupt, partner at Everoze and board member at Skyray, argues that investors and lenders have to start making decisions today to fulfil the disclosure regulations required and making sure their fleet is providing a positive impact on biodiversity. The key challenge is to weigh the techno-economic-ecological risks, opportunities, costs and revenues attached to each.

SFDR and NFDR [1], EU taxonomy, Green New Deal, COP15 and COP26 [2], Equator Principles, TCFD and TNFD [3]… To be honest, keeping track of the whirlwind of ecological sustainability regulations and recommendations can be a real challenge. One thing is clear, the application of the do-no-significant-harm principle of the EU taxonomy [4] means that, whilst solar PV significantly contributes to at least three of its six environmental objectives, the activity will need to prove no significant harm comes to any of the other three objectives. Given the scale of growth and demand for land resources, a particular focus for solar PV is likely to be the protection and restoration of biodiversity and ecosystems.

Since publishing the “PV for Future” article in the January 2021 edition of PV Magazine International, which argued that putting ecological sustainability at the heart of PV project planning and operation should become the new industry standard, the situation after 9 months has already changed.

Back then the question we asked was “Are you ready to be part of PV for (a) Future”? The focus today has turned to “Are you already part of PV for (a) Future”?

Given that the first EU Taxonomy disclosures are due by the end of 2021 and throughout 2022, it is key to start aligning with its rather complex and extensive framework as soon as possible. Already in the near-term the financial industry will allocate capital dominantly towards the best of the best in terms of biodiversity and wider ESG aspects (environmental and social governance).

PV projects have been recognised by multiple studies [5] as a contributor to improved biodiversity outcomes, when done right. Aside from the German and Spanish solar industry associations BNE and UNEF, which published in 2020 and 2019 respectively best practice checklists for PV developers and owners to incorporate environmental benefits, further industry guidelines have followed suit. In May 2021 Everoze co-authored the sustainable agrioslar best practices guidelines [6] and the sustainability best practices benchmark [7], published by European solar association SolarPower Europe, both putting an emphasis on biodiversity measures and environmental and ecosystem services of solar parks.

So what can solar investors and lenders do to provide evidence of their biodiversity actions? What will the “best of the best” solar projects be doing for biodiversity?

To start with, there is a low-hanging fruit at low cost and small effort. On the other side, there are big impact measures that may in some cases require a painful cut to installed capacity, and hence revenues. With a current lack of revenues attributed to necessary biodiversity measures, the decision making is complex. One the one side it depends on the level of commitment of the investor or lender, but on the other side the decision making may be influenced by the need to potentially make up for a more harmful rest of the portfolio.

Low hanging fruit

What measures actually enhance the biodiversity of a solar park, that go beyond the mitigation requirements from the environmental impact assessment?

There are some easy and straightforward answers. Studies have shown the clear benefits of less frequent grass cutting, mowing later in the year or changing the mowing techniques to more insect friendly methods, for example, by leaving the clippings or using specialised machines. It has also been shown that not using fertiliser and pesticides, as well as planting and maintaining wild flower and nectar seed meadows (with local seeds) are beneficial to fauna and flora. Clear commitments to not using toxic and only environmentally degradable cleaning products are clearly linked to biodiversity and ecosystem enhancement. Allowing safe wildlife corridors for crossing animals to connect habitats are also in the range of easily understandable and implementable measures. Other measures around installing and maintaining animal shelters such as bird houses, ponds, bat boxes, insect hotels or stone piles for lizards also only create a minor increase in opex.

Detailed understanding of the local environmental conditions is critical to ensure that a given measure delivers maximum ecological benefit, and even to mitigate against potential harm from badly designed or implemented interventions.

Big impact decisions

Some of the big impact measures however, such as increase in panel row spacing or reduction in ground cover ratio, stir up heated debates, since these have a direct impact on the installed capacity of the plant. How much light is required to spur biodiversity and what about differing climates? The benchmark of 1 ha for 1 MWp installed PV as recommended by the German BNE guideline seems rather unambitious [8]. The recommendation from the Spanish solar association UNEF of 2.5ha per MWp installed on flat terrain takes into account the use of tracking and bifacial technology and higher irradiation angle, and allows for more sunlight to hit the ground. Or should the limitation be rather related to the module cover, as outlined in the SolarPower Europe agrisolar guideline, of 50% for south-north and of 60% for east-west facing ground-mounted systems? And what does this cover include exactly?

In light of competitive PV tenders, cut-throat negotiations around corporate PPA terms and lack of compensation for biodiversity and ecosystem protection measures, reducing the installed capacity for biodiversity measures are clearly hot potatoes.

PV for Today

With the “EU sustainable finance disclosure regulations” coming into force on March 10, 2021 new transparency rules on the effects of sustainability risks in financial investment products and adverse effects have been established. With the recent publication of the “biodiversity target setting” guide as part of the UN principles for responsible banking, it is recommended to assess and improve all solar PV projects to ensure they are truly sustainable across the spectrum of ecological objectives and financeable into the future. Simply relying on the belief that solar is ‘green’ enough because of the zero-carbon electricity it produces is no longer enough.

A holistic techno-commercial-ecological approach is required. With the help of a recently developed biodiversity decision management support tool our team can now add the ecological perspective to the Technical Due Diligence scope of reviewing technologies, production, contracts, permits, financial models, or business cases, and supported by external experts where required.

Clearly, this is just a first step for the solar industry in minimising damage or regenerating the depleted environments of today’s world in a climate and ecological crisis. On top of biodiversity measures, further action is required for example around wider ESG aspects, such as carbon footprint accounting, supply chain tracking and lifecycle assessment – all by looking beyond and keeping a holistic mindset.

[1] EU Sustainable Finance Disclosure Regulations applicable from 10 March 2021, EU Non-Financial Reporting Directive

[2] COP 15 UN Convention on biological diversity mid October 2021, COP 26 – UN Climate Change Conference end of October 2021

[3] (International) Task force for Climate-related disclosure, (International) Task force for Nature-related disclosure

[4] EU Taxonomy applicable by the beginning of 2022

[5] Solar Park Impacts on Ecosystem Services project

[6] SolarPower Europe Agrisolar

[7] SolarPower Europe Sustainability

[8] BNE Gute Planung