CONTRIBUTIONS OF STRATEGIC ENVIRONMENTAL ASSESSMENT TO ENERGY PLANNING IN BRAZIL: TOWARDS A SUSTAINABLE APPROACH
ABSTRACT: This work discusses how Strategic Environmental Assessment (SEA) concepts may contribute to a more sustainable energy planning in Brazil. The energy expansion strategy adopted in the National Energy Plan (PNE 2030) has been presented polemic because of environmental and social costs.The current model prioritizes the implementation of hydroelectric plants in high socio-environmental susceptible regions such as the Amazon.
The Brazilian Energy Planning was understood to make this analysis, regarding the opportunities for insertion of environmental and social aspects in strategic decisions. It was also submittedto a comparison with the Dutch case, which has extensive experience in the application of strategic approaches to impact assessment. Based on the comparisons made, it was possible to conclude that the Brazilian energy sector still faces many strategic challenges, not only related to the observation of sustainable developmentfundamentals, but also due to presenting a planning model with few opportunities for social and environmental variables insertion. This model also indirectly prevents the sector to achieve its own goals and objectives as witnessed by the fact that, although the PNE is in its first implementation stage, the country is heading a major energy crisis.
This article concludes by identifying elements of the SEA and the Dutch energy expansion process that could contribute to a strategic sustainability reach in the Brazilian energy sector.
RESUMO: Este trabalho discute em que medida os fundamentos da Avaliação Ambiental Estratégica (AAE) podem contribuir para a inserção da sustentabilidade no planejamento energético brasileiro. A estratégia de expansão energética adotada no Plano Nacional de Energia (PNE 2030) tem se apresentado polêmico devido aos custos ambientais e sociais. O atual modelo prioriza a construção de usinas hidrelétricas em regiões de alta suscetibilidade socioambiental, como a Amazônia.
O planejamento energético no Brasil foi interpretado em relação às oportunidades para inserção de aspectos ambientais e sociais nas decisões estratégicas, tendo sido submetido em seguida a uma comparação com o caso Holandês, o qual apresenta vasta experiência na aplicação de abordagens estratégicas de avaliação de impacto. A partir das comparações efetuadas, foi possível concluir que o setor energético brasileiro enfrenta ainda muitos desafios estratégicos, não somente relacionado à observação dos fundamentos do desenvolvimento sustentável, como também em função de apresentar um modelo de planejamento com poucas oportunidades para a inserção das variáveis socioambientais. Este modelo também impede de forma indireta que o setor atinja suas próprias metas e objetivos de expansão energética e isso pode ser constatado pelo fato de que, embora o PNE se encontre em sua primeira etapa de implantação, o país caminha para uma grande crise energética. O trabalho conclui apontando elementos da AAE e do processo de expansão energética holandesa que poderiam contribuir para um alcance estratégico da sustentabilidade no setor energético brasileiro.
KEYWORDS: Energy Planning, Strategic Environmental Assessment, Sustainability.
PALAVRAS-CHAVES:Planejamento Energético, Avaliação Ambiental Estratégica, Sustentabilidade.
INTRODUCTION AND THEORETICAL BACKGROUND
In recent years, Brazil had faced a great economic growth and, to support the development of the country, the energy expansion became the main goal of last governments. However, the strategy adopted by the Ministry of Mines and Energy (MME) is current generating many conflicts andsocial-environmental impacts.
Brazil has a huge hydroelectric potential, but the National Energy Plan (PNE 2030) states that around 70% of it has not been explored yet. Hydroelectricity is usually considered a renewable and clean source and has much international support for its exploitation such as investments from carbon market. Moreover, the production of electricity from this source is comparably cheap, which led the government to prioritize hydroelectricity on its energy expansion plan.
However, most of the remaining potential is located in the Amazon, the largest rain forest in the world, which has rich biodiversity and where most of Brazilian indigenous people live. These exploitations have been accompanied by countless impacts and conflicts in the region, leading many experts to question the strategy considered sustainable by the government. Moreover, the delays caused by those conflicts, in addition to the poorly diversified energy mix, are currently heading the country towards huge electricity crises.
The Strategic Environmental Assessment (SEA) has been emerged as an important tool to improve the sustainability approach and global impact analysis on Policies, Plans and Programmes (PPPs). The Netherlands has a long experience with SEA, as it started been implemented on its institutional framework in 1987. That said,the Dutch approach on SEA was considered the main reference for this study.
This research aims to analysis the ways SEA could promote the insertion of sustainability issues on Brazilian energy planning.
METODOLOGY
In order to consolidate a critical view and to draw up a proposal for implementing SEA in the Brazilian energy planning, it was necessary to search for background information. The study was divided into three steps, described below, and aimed at the generation of two products: a comparison between Brazilian and Dutch systems and recommendations for the Brazilian Energy Sector.
At the first step thehydropower implementation process in Brazil was studied, as well as the National Energy Plan (PNE 2030) for hydropower plant, in order to give a clear understanding of the challenges faced by the energy sector towards sustainable development.
After that, SEA concepts were explored through the SEA Open Educational Resource developed by the United Nations University and Oxford Brookes University as well as some reading materials from SEA training courses. To understand the feasibility of using this tool in Brazil, the SEA experience in energy planning in several countries was studied, including the Netherlands.
In the third stage, the Dutch approach on SEA and its energy expansion process were studied in order to accumulate enough knowledge to support the comparison between its system and the Brazilian´s. At this phase it was essential the guidance of a Dutch consultant, Geert de Vries. In addition, the NCEA (Netherlands Commissionfor Environmental Assessment) consultant Sjoerd Harkema answered questions about operation of SEA and Dutch Energy Planning in an interview to clarify some specific points.
RESULTS AND DISCUSSION
The Brazilian energy expansion process takes place as shown in scheme of Figure 1. The federal government defines the Energy Policy and MME prepares the National Energy Plan (PNE), for a horizon of about 30 years and, based on it, also prepares the Decennial Energy Plan (PDE), with more detailed strategies. The next step is the Inventory Study when it is studied the optimal way to explore an specific water basin, defining new hydropower plantslocations and their energy generation capacity. These possible exploitations are forwarded to the Energy Auction after its Feasibility Study being approved by the Ministry of Environment (MMA).
Figure 1right column shows how the environmental assessment takes place in the current model. It can be observed that the consideration of environmental aspects in Brazilian energy planning has improved through initiatives such as the insertion of Integrated Environmental Assessment (AAI) for Inventory Study.However, the sector still has to face many challenges to reach a satisfactory sustainable development.
A limited participation of environmental experts in scenario analysis and strategic decision can be observed. The environmental assessment mainly through licensing is extremely reactive as it actsjust in the final stages of the expansion and its function isn´t contributing to a more sustainable strategic solution for sector, but finding failures on projects and mitigate environmental losts. That said, the adoption of an energy matrix predominantly hydroelectric in the PNE 2030 is questioned by the environmentalists, energy specialists and society because of its regional impacts and the distance between plants and consumer.
On the strategic front, dialogue amongstakeholders should increase. Currently each Ministry makes a different plan for the same region without confronting information and without consulting other interested goups. The absence of confrontation postponesdivergencesresolution to project phase. As a result,it causesdelays in licensing,project execution and prevents each sector to achieve its targets and/or deadlines.
In the implementation stage, the system should be more strict, because eventually strategic decisions are ignored and changes in design phase are done. These changes imply a number of unforeseen impacts and also prevents global goals achievement.
PNE 2030 raises a couple of uncertainties regarding the adopted energy expansion strategy:
- Environmental licensing: licensing for hydroelectrics is slower than for other energy sources due to the high complexity of its projects and larger impacted area. Delays occur frequently also because environmental reports usually are of poor quality and sometimes changes on location and generation capacity happens at project phase,after Feasibility Study being approved by MMA.
- Regional conflicts:population from Amazon and environmental agencies often question the construction of the plantsin the area. Not just forits large impact, which is not all mitigated or compensated, but also because most of the damsaims totransportenergy to the country Southeast. That said, the plants construction are usually intervened by strikes, riots and judicial processes.
- Energy efficiency: electricty transport has a separate licensing process than its plants. That sometimes also resultsin delay in providing the energy produced to costumers. Furthermore, the electrictytransport is not guaranteed bytransmission lines construction, as Brazil has an energy loss of approximately 20%, according BERGMANN (2012), due to the vast distance to cover and the lack of maintenance.
- Clean and cheap energy production: a predominantly hydroelectric matrix is subject to climate change and also to a great drop in production at reserviors downturn, which leads the energy sector to resort to emergency plans to provide suficient electricity suply. Usually, in Brazil, thermal plants - powered by oil, gas, coal and nuclear fuel - are used to meet the demand in this case. That makes this strategic choice unsustainable, as it is always falling back on highly polluting and expensive sources, since thermal electricty production from these sources does not have a competitive price and in some cases requires raw materialsimportation.
The Madeira River hydroelectric complex is a clear example of how the strategy adopted may compromise PNE 2030. After the Energy Auction, Santo Antônio and Jirau plants, one upstream of the other, requested to increase their electricity generation capacity resulting on local conflicts, irreversible environmental and social impacts and, last but not least, licensing delays longer than expected. Thatcompromised thedelivery deadline ofthe plants were flagships of last governments. As the Madeira River Hydroelectric Complex, other powerplantsfrompriority basins (that has no impact on Preservation Units or Indian Reservations), such as Belo Monte, have facessimilar problems.
Most of the problems faced by Brazilian energy sector are due to its extremely reactiveenvironmental assessment. SEA, on the other hand, proposes a more proactive role forit. This tool aimsto support various sectors on decision making by introductin social and environmental concerns in PPPs. Therefore, SEA enable each sector to have its own global target for sustainability.
The Dutch experience on SEAhelps to understand how this tool can contribute to Brazil overcome the challenges faced by energy sector. In the Netherlands, the energy sector targets are confrontedwith other sectors’ ones and, with all Ministries contribution, it is made the National Spatial Plan, as shown in Figure 2. This plan aims theresolution of conflictsand the adoption of a balanced strategy that meets the needs of each sector. It also relies on the involvement of experts, population and Netherlands Commission for Environmental Assessment (NCEA).
NCEA acts as an independent consultant body responsible for the implementation of SEA. It acts not only in the spatial planning stage, but in all strategic decisions (PPPs) until reach the project phase, where project-EIA is responsible for the assesment. Despite having no decision power, NCEA contributes by proposing more sustainable alternatives, which may be followed by the government.
This proactive approach together with effective hierarchy between the planning bodies makes the Netherlands a successful example of SEA application, enabling the achievement of each sector global targets after the implementation of each project.
From the Netherlands example, therefore, it can be concluded that to Brazilian energy sector achieves its goals, they must be in line with other sectors goals. The hydropower potential exploitation presents a high uncertainty degree as it can be remarked in the way the MME plans the hidreletric expansion at PNE 2030:
•“From 2015 to 2020, plants located preferentially in priority basins and without any interference (Conservation Units and/or Indigenous Reserves) can be built;
•“From 2020 to 2025, it is expected that projectsfeasibility conditions will be reviewed, through the regulation of Federal Constitution Article 231 and environmental norms,allowingpower plants constructionnearby Indigenous Reserves and in Sustainable Use Protected Areas;
•“From 2025 to 2030, the dams construction initiated in the previous period maycontinue and it will be complemented bythe construction of plants with any interference, considering that design optimization studies or changes in legal and regulatory requirements will take place.”
First of all, it is assumed that changes in constitution will allow the construction of new damsclose to or with any interferencewith protected areas. Those changes thus depends on other sectos agreement so it may not happen on the way and time expected by MME, compromising the energy sector goals. Furthermore, even focusing on priority basins exploitation, the PNE current implementation phase have been ineffective as it presents many delays, conflicts and rasescountless questions.It is expected thenthat future exploitations, in non-priority basins, present a worsening of these problems and, therefore, longer delays.
CONCLUSIONS AND RECOMENDATIONS
The results indicate that the Brazilian energy sector faces many strategic challenges, not only related to sustainable development, but also to the quality of the planning itself, which lead the energy sector to resort to emergency plans to achieve its expansion goals. Instead of consider SEA as a barrier to economic growth, the sector should recognize this tool asa solution to more effective estrategies that enable the achievement of sustainability in planning as well as its own energy expansion goals.
PNE 2030 has barely began to be implemented and it is already associated withcountless conflicts, impacts and delays, which indicates a high level of uncertainty about its outcome, especially regarding the incorporation of environmental concerns into strategic decisions. The Netherlands, in turn, has a very structured system with a sucessfull use of SEA as well as an effective hierarchy between planning bodies. Many elements of SEA and the Dutch energy expansion process could help to expand the sustainability strategic reach in the Brazilian energy sector.
Based on studies and on PNE 2030 energy expansion outlook, recommendations are made for implementing SEA gradually:
- 2015-2020 –Being stricter to what was defined at Inventory Studies, not allowing changes in project phase. That could avoidunpredictable impacts, such as occurred at Madeira River Complex,contributing to the achievement of global goal of sustainability and preventing unpredictable delays.
- 2020-2025 - Confronting each Ministry plan to define the best spatial planning for Amazon region, discussing the best scenario for the next exploitations. This analysis may consider the energy matrix diversification to define a balanced solution for all concerned stakeholders and, at the same time, ensure energy supply.
- 2025-2030 - Using the Dutch concept of independent advice, with participation of experts, society and NGOs, to enable the energy sector to met its goals on time and in a more sustainable way, avoiding as much as possible the direct interferencesin Conservation Units and Indigenous Reserves.
These interventions will result in a more satisfactory outcome for society, environment and indeed energy sector. More over, they will enable the construction of a“Brazilian Experience on SEA Manual”, which can be used as a learning guide and improve the use of this tool over time.
REFERENCES
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