Shulman Advisory

Not in My Backyard, Japan Style

At the end of May, Nikkei reported that the number of local government ordinances in Japan banning renewable power plant construction has reached about 60, double what it was in 2017.

What could be driving this trend in a country where much of the populace is eager to move beyond its past dependence on nuclear power?  Today we’re going to pick apart what’s going on here.

We’ll start by looking at the history of environmental assessment regulations in Japan.

National Environmental Legislation – Bringing up the Rear

The worldwide trend toward the requirement of environmental impact assessments (EIA) began with the enactment of the National Environmental Policy Act in the US in 1970.  Within five years, similar legislation had been enacted in Australia, New Zealand, Malaysia, and India, and many other countries followed suit later in the 1970s and into the 1980s.  Though by no means the last, Japan came rather late to the party in 1997 with its Environmental Impact Act.

Notably, solar plants only became subject to national environmental impact assessment requirements in 2020, eight years into the feed-in-tariff program which catalyzed the expansion of renewables in Japan, and as the government is preparing to wean solar development off of FIT and onto a more modest feed-in-premium regime.

This is all the more curious when one considers that as of the end of March 2017, non-residential solar accounted for about 81% of the growth in renewables under FIT.  Wind power, which only accounted for about 2% of growth by that time, had become subject to national EIA requirements at the beginning of FIT in 2012.

It’s strange to look back at a period of historic growth in solar generation in Japan to see EIA submittals only for other types of power generation.

We’ll set aside the question of the reasons behind this inconsistency for the moment, but in any case, it’s easy to understand why in this context local governments felt compelled to institute their own environmental regulations for solar plants, which they started to do in 2014.

EIA Requirements in Action

At a glance, Japan’s EIA process, though complex, doesn’t look much more complicated than that in the US or in many other developed countries.

However, it’s important to note the multiple junctures at which prefectural governors and mayors of municipalities make input into the process, which they sometimes use to grind the process to a halt.

Another important aspect to note is that power plants subject to EIA requirements are grouped into Class 1 and Class 2 by plant output.

Whether or not Class 2 plants are subject to EIA requirements is left to the discretion of the Minister of Economy, Trade and Industry.

That bears repeating:  Whether power plants of a certain size are subject to environmental impact assessment requirements is decided not by the Ministry of Environment, but by the Ministry of Economy, Trade and Industry (METI).

Local Objections to Solar Plants

Specific Cases

The reasons for local opposition to solar plants have been varied, as have the parties lodging the concerns.

Concerns have grown since a number of plants were damaged in natural disasters in 2018.  (Notably, only plants above 50 kW are required to report such damage to the government.)

High profile cases included extensive damage to a 750kW plant in Hyogo prefecture caused by a landslide resulting from heavy rains; scattered panels and fire at a 6.5 MW plant in Osaka City caused by a typhoon; and a 1.9 MW plant in Osaka Prefecture becoming unmoored and hundreds of its panels flipping over due to the same typhoon.

A Larger Story

If one steps back and looks at the bigger picture, there’s a story at play that’s larger than the specific circumstances of any one case of local opposition or of damage to a plant.

This is a story of local community residents and their leaders feeling neglected, and sometimes even willfully ignored, by a central government which prioritizes economic concerns above all else to the point of taking important decisions about the applicability of EIA requirements out of the hands of the Ministry of Environment and putting them with METI, in full view for all to see.

The government’s decision to make solar plants subject to EIA requirements just as the solar construction boom is tapering off only serves to underscore these communities’ sense that they’ve been disregarded.

The point for many of these local stakeholders is that they feel ignored or dismissed.  That the projects in question are renewable developments which can help Japan move beyond nuclear and coal is secondary.

Even in Japan, a country whose energy situation is best known for a nuclear accident and popular desire to move beyond nuclear power, don’t underestimate the importance of local stakeholder engagement in renewables development.

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