Alcoutim Solar mega-project 'an unsustainable and unreliable misfit'

Eco-organisation Almargem has come out against the huge solar park planned for Alcoutim area, especially as nobody seems to know who is behind it.

"The Almargem Association has issued a negative opinion on the environmental impact study of the proposed Alcoutim Photovoltaic Centre that recently was under public discussion.

At issue is the construction of a solar 'mega centre', which plans the occupation and complete destruction of an area of 600 hectares of Algarve countryside with the installation of approximately 2.4 million photovoltaic panels to produce 220 MW of electricity, more than four times the installed power of the Solar Centre in Amareleja.

Obviously, Almargem supports the increase in energy production systems that do not involve fossil fuels but for every situation it is necessary to weigh all the pros and cons.

In a territory such as the Algarve, it is preferable to choose to deploy smaller solar plants in abandoned agricultural areas of no conservation value and close to places of consumption where all the stakeholders can have benefits and where any negative impacts are considerably lower.

In the case of Central Photovoltaic plant for Alcoutim, it is to occupy a territory where the terrain is extremely rugged and inappropriate for such a project. In addition, there are nuclei of great archaeological importance which have yet to be fully studied, as well as nature and landscape worthy of preservation. In particular, this case involves the destruction of many habitats protected by national and European Community legislation and the felling of thousands of cork and holm oak trees, species protected by law and also the inevitable death of many thousands of terrestrial fauna present in the area.

Simultaneously, it is considered incomprehensible that the proposed technology for this megacentre is already rather obsolete with more efficient equipment on the market capable of producing the same amount of energy but taking up less area, which inevitably would help reduce its environmental impact.

Another important issue is the direct effect on a section of the Via Algarviana walking route between Vaqueiros and Furnazinhas which inevitably will lead to a lower demand from potential walkers who will not be interested in having to go through an industrial facility of this size. This will have a serious impact on the local economy of the villages in the area.

The planned investment of more than €200 million is primarily to purchase imported equipment so a significant economic or social contribution to the area of Vaqueiros, Martim Longo and Alcoutim is not envisaged.

Finally, Almargem believes that the planned compensatory measures are absolutely ridiculous and not appropriate to the size of the project and there has been a lack of information regarding the details surrounding these in particular with regard to the unknown company promoting the scheme which is registered with a low ‘social capital’ figure and which has declined to explain to the local villagers who is behind the company.

Almargem Association
R. de S. Domingos, 65 - 8100-536 Loulé
Tel. 289412959
www.almargem.org

(Contact: John A. Santos - 964 584 528)

Conclusions of the Environmental Impact Assessment (rough English translation)

The Almargem Association believes that the Ministry of Environment should issue an unfavorable opinion on the present EIA and the project behind it.

Among other reasons that support our position, we summarise as follows:

- Doubts about the suitability of the promoting company, particularly in terms of their actual investment capacity and lack of transparency and dialogue;

- Exaggerated size of the project, calling into question the basic principles of sustainable development;

- Doubts about the effective balance of carbon accounting, taking into account the complete destruction of vegetation in the 600 hectares of the project;

- Inefficient use of photovoltaic technology relative to other options already existing on the market;

- Absence of a broad discussion on possible alternatives to the project in terms of location and decentralization;

- Project incompatible with the standards listed in Alcoutim PDM on the use of natural spaces;

- Complete inadequacy of the morphology of the territory for an intervention of this nature and scale;

- Allocation of various habitats protected by national and Community legislation;

- The need to slaughter thousands of protected tree species (holm oaks, cork);

- Reallocation of several dozen wildlife species protected by national and Community legislation;

- Predictable death of thousands of amphibians, reptiles and small mammals and the destruction of breeding sites and resting birds;

- Devastating impact on the landscape;

- Valuable archaeological allocation, with eventual destruction of areas of importance not yet been properly evaluated;

- Severe disruption of the Via Algarviana, with direct impacts on the local economy;

- Absolutely ridiculous compensatory measures on the scale and impact of the project.

September 2015

Foreword to the comments on the  Environmental Impact Assessment

The Association Almargem does not understand how a project of this nature and dimension can be promoted by an unknown company, whose registered office is an accommodation address and which has negligible capital. What guarantees are given regarding the investment of €220 million and the provenance of that money? What guarantees are there that this is not just a ploy to obtain building permits which later will be transferred to another company?

The fact that the company Solara4 and its management has not made a point of saying who is behind the company raises more doubts about the real intentions behind the project.
It is unfortunate that the Ministry of Environment agreed to move forward with this process, without requiring greater transparency and public accreditation of the promoter.

Decentralized systems vs concentrated systems
Almargem supports the development of initiatives to strengthen the solar component in the power generation system in Portugal and, in particular, in the Algarve, taking into account the urgency to bring down atmospheric carbon production levels from the use of fossil fuels.
From our point of view, one of the energy policy priorities in our country should be to support the installation of decentralised systems of photovoltaic power generation in urban, residential and non-residential spaces, with the possibility of connecting to the national grid and obtaining the proceeds arising to the benefit of family budgets and the companies or institutions involved.
We are also in favor of building small solar power plants in abandoned agricultural land or without any conservation interest, capable of producing enough electricity to supply neighbouring villages.
 Building solar mega centres is just an ‘easy profit’ business and not compatible with the basic principles of sustainable development.

In recent years there has been an increase in solar energy production systems classed as large scale, or USS ("Solar utility-scale"). Just remember that the Solar Centre in Amareleja when it first opened in 2008 was the largest photovoltaic plant in the world with 47 MW.
Today, after only seven years, that title is held by Solar Star (USA) with 579 MW and there are plans for dozens of other mega centres, some with over 1 GW of power.

According to proponents of the USS option, these systems supply energy at half the cost of the equivalent production from decentralized systems.

This lower cost is due to economy of scale and greater efficiency of the panels due to their optimal orientation relative to the sun.

However, this cost comparison does not take into account factors that characterise large scale systems such as the need to occupy additional land for the construction of power lines for grid connection, the high losses that occur in the transmission of energy due to the distance between the producer and the consumer, of adapting production to fluctuations in electricity consumption throughout the day or year and the minimisation of costs in case of failures in production or transportation of energy, since any power cuts affect a smaller number consumers thereby improving the overall quality of service.

Importance of this Environmental Impact Assessment (EIA)

Since this is a recent technology option, large scale photovoltaic systems do not benefit from any consolidated experience in the evaluation of their environmental impact, especially as larger plant have been installed in desert or near-desert areas.

The proposed photovoltaic plant in Alcoutim and this EIA therefore are particularly important, and the assessment should not be views by the Ministry of the Environment as a mere bureaucratic formality given the unusual dimensions and location of the project.
In addition to putting the EIA up for public discussion, the Ministry of the Environment should have organised together with Solara4 and Matos, Fonseca & Associates (the EIA author), project presentations in order to evaluate environmental sustainability.

What is at stake is the construction of a USS system with an installed capacity of 222 MW, generated by 2,393,700 photovoltaic panels, occupying an area of 600 hectares. If today this plant already was in operation it would be the largest photovoltaic plant in Europe and one of the 12 largest in the world.

For purposes of comparison it should be noted that in Portugal the largest facility producing electricity is the Sines Thermal Power Plant with an installed capacity of 1,192 MW and fueled by coal.
In the Algarve, the Thermal Power Plant in Tunes is powered by diesel and produces 200 MW of power held in reserve. The largest Portuguese dam (Alto Lindoso) has 630 MW total power output.

Solar Demonstration Platform in Alcoutim

The Solar Demonstration Platform of Alcoutim (PDSA) occupies 42 hectares along the EN 124, a few kilometers from Martimlongo and was inaugurated in 2013.

It is managed by Eneralcoutim company created by people previously linked to the Algarve Energy Park project in Portimão which failed to materialise. This initiative was funded by OP Algarve 21 and cost about €13 million.

In the first phase about 8 hectares of photovoltaic concentration panels (CPV) totaling about 4 MW of power were installed by Magpower and Sunalcoutim.

The CPV technology uses optical devices to focus sunlight on small photovoltaic cells to produce electricity. Although the equipment is more expensive, the efficiency of these panels is far superior to traditional photovoltaic panels, such as those intended to be installed in Alcoutim, thus saving substantially on the number of panels needed and the space to be occupied.

For a plant with installed capacity of 200 MW, the use of CPV systems means that an area of about 400 hectares is needed instead of the 600 hectares needed for the Alcoutim project.

Besides, what sense does it make to have spent millions of euros in Martimlongo, a cutting-edge solar technology demonstration park, and right next door to install a solar mega centre with technology that is, or very soon will be obsolete.

It should be noted that the Solara4 company chose the cheapest option, not the most advanced.

The panels to be used are of American origin, supplied by First Solar. If the most modern panels were used (FS392, 92 W) for a 215 MW power output,  2,341,662 panels would be needed.

In the case of panels provided for the project (FS390, 90 W) for a 215 MW power output, 2,393,700 panels are needed.

The difference is 50 thousand panels, a saving of about 12 hectares.

Assuming that losses in centrally produced energy distribution systems are 8.16% (national average of the actual value of the losses in 2010), opting for a decentralised production close to the place of consumption would mean a saving of nearly 200,000 panels, equivalent to more than 40 hectares.

Alternatives to the project

Taking into account what was said in the previous section, the EIA is clearly inadequate and insufficient as regards the exposure of possible alternatives to the project. In terms of technical alternatives are only very briefly mentioned production systems based on fossil fuels and hydropower. As for the location alternatives that nothing is concrete.

It is especially incomprehensible that the existence of alternatives are not mentioned such as those patents in the Solar Demonstration Platform of Alcoutim, a project which, incomprehensibly, is not even mentioned in the EIA.
As to the site, the exaggerated size of the project does not really leave many alternatives as it would not be easy to find in the Algarve another available large estate of hundreds of hectares. But this is an inherent difficulty of the dysfunctional and unsustainable characteristics of this solar mega centre.

Another aspect that is not properly explained in the EIA has to do with the reasons why the promoter decided to concentrate the solar plant in only half of the property, with the equipment to be installed near neighboring properties which are used for hunting.

PDM Alcoutim

Confronting the deployment area of the Photovoltaic with classes provided space PDM Alcoutim, 479 ha (about 81%) coincide with agro-forest areas assigned to multiple use spaces in which priority should be given "forest use traditional multiple use of Mediterranean formations, as well as the maintenance of traditional agricultural uses, particularly in terms of use of bark and fruits, firewood, hunting exploration, forestry and grazing, beekeeping, honey plant species, aromatic, culinary and medicinal, notwithstanding land conversion measures and protection and natural regeneration and the introduction of native plant species; They should also be undertaken land conversion measures which are designed to diversify the cultural mosaic, including the implantation of forest species, the maintenance of open spaces and the realization of small irrigation schemes ".

Note that these areas are "allowed to carry out construction works to public or private facilities for collective use and public territorial infrastructure or private, recognized municipal interest, provided there is no viable alternative to installing them and its location is based on a study of environment and environmental impact assessment to ensure in particular its proper integration in the surrounding. "

Other 114 ha (about 19%) of Photovoltaic would take natural areas to safeguard and biophysics activation, which, according to the PDM must be "preserved its natural characteristics, in order to ensure their own values and the balance environmental and landscape, also taking into account that these areas also perform management duties and additional protection of municipal biological reserves "and" enhanced species and no traditional cultural practices of indigenous vegetation structures and prohibited ".

These areas are spaces "non aedificandi", only being allowed to perform work pursuant to Article 43-D of PDM Alcoutim Regulation, and the Photovoltaic does not fit into therein and for the edification exceptions in rural land.

So that this project could move forward would thus:

- Be considered as collective use of equipment;
- Be recognized its municipal interest;
- Be provided for integration in the surrounding;
- To change the PDM in terms of areas of natural vocation.

Even though the Municipal Assembly of Alcoutim could come to recognize the public interest of the project and approve a PDM amendment to change the land use in a substantial part of its deployment area, you can not understand how a solar megacentral 600 ha can be considered a collective use equipment and to become properly integrated into the surroundings.
To emphasize that any change to the PDM which may have significant effects on the environment, as would be the case, you must first be subjected to a process of environmental impact assessment.

Vegetation

In about 600 ha of the deployment area of the Photovoltaic, vegetation would be completely removed and prevented its regeneration. Taking into account that this is not a flat surface but strongly wavy, soil erosion rate would be very high.

As Minimizing measure is ensured planting herbs in the whole area. but they are not specified management measures to be implemented such as the frequency of weeding and the compatibility of this measure with the regular cleaning tasks of the panels. Most particularly, it is not properly explained the procedure to be used in regular clearing operations, assuming that will not be used only scrub-clearing machines woods, as indicated in the EIA, given the cost inherent in this operation, and actually come to resort to pesticides, whose environmental impact in an area of this size would be very significant.

The main arboreal stands and shrubs to destroy the central area of deployment would be as follows:

- Cistus (235 ha)
- Tame pine forest (91 ha)
- Holm (55 ha)
- Azinhal + pine forest (101 ha)
- Sobreiral + pine forest (96 ha)
- Scrub and riparian vegetation (12 ha)

Some of its natural habitats destroyed are protected by national and Community legislation (Directive 92/43 / EEC, Decree Law No. 140/99 of 24 April as amended by Decree-Law No. 49/2005 of 24 February) in particular:

- Habitat 6310 (Quercus spp Mounted of evergreen.).
- Habitat 91B0 (Freixiais thermophiles of Fraxinus angustifolia).
- Habitat 92D0 (Southern riparian galleries and thickets (Nerio-Tamaricetea and Securinegion tinctoriae).

To point out the allocation of about 250 ha of pure and mixed stands of oaks and cork oaks, with slaughter of thousands of trees, which also implies a prior opinion of the ICNF.

Fauna

With the destruction of vegetation cover, would be affected all existing terrestrial fauna in the 600 central deploying ha. Amphibians, reptiles and Micromammals would be killed by the thousands. Macromamíferos and birds could eventually leave the area, but their places of refuge (burrows, nests) would also be destroyed, including juveniles housed.

Although the EIA is considered that the project's impact on wildlife would be negative and high magnitude, are not adequately addressed the fifty species listed in Annex 5.2. and that are included in Annexes I, II-B and B-IV Directives of the Birds and Habitats (Decree Law No. 140/99 of 24 April as amended by Decree-Law No. 49/2005 of 24 February), the which can not be targeted for killing, disturbance of their habitats, destruction of breeding sites and resting, all of which put itself on the legality of this project.

Landscape

Contrary to this project, most solar megacentrais built over the past few years, has been deployed in desert or prédesérticas areas and also in areas with previous agricultural occupation. It is more or less flat surfaces, which facilitates the work involved every stage work and subsequent operational stage. Moreover, the visual impact on the surroundings is substantially reduced.
Apart from the obvious inadequacy of the territory in this type of project, involving the occupation of 600 hectares of hilly terrain with 2.4 million photovoltaic panels, it must be emphasized the absolute impossibility in this case minimize their visual impact.

Archaeological heritage

In the central area of deployment, they are known three cores with greater importance archaeological point of view, namely:
- Castle of Santa Justa
- Village Moorish
- Mines harness

To the Castle of Santa Justa, Chalcolithic settlement classified as a Public Interest (Decree 29/90, DR, Series I, No. 163 of 07.17.1990), which occupies a marginal serro Area deployment, but whose landscape involvement would be seriously affected, only provides for the rectification of the existing fence.

In the case of the Moorish village with well-preserved remains of a medieval Islamic settlement, the draft does not provide for the installation of panels in the area that has been subject to archaeological surveys but can only represent a small part of the rich heritage that exists here.
Mines in the harness, explored in the century. XIX, only foresees a survey "for future memory," before this area is completely devastated, as were other events that may eventually be found during the clearing phase.

Via Algarviana

Via Algarviana is a Great Pedestrian Route (GR 13) with a length of about 300 km, between Alcoutim and Cape St. Vincent, promoted by Almargem Association, which aims to raise awareness of the natural heritage, landscapes, culture and traditions of the Algarve interior, contributing to the sustainable development of the region.

It is a project that was funded by the EU and by municipalities, reaching an investment of over one million euros.

The Alcoutim Central Solar intends to occupy 1.2 kilometers from this prestigious route, it being said in various parts of the EIA and classified, in the general framework map of the project as "way to benefit."

However, nothing is said about the impact that the central crossing can have on the future use of the Via Algarviana in this region, nor what kind of "upgrading" the current path may suffer.

In the area concerned, Via Algarviana already plays a major role in boosting the local economy, particularly in terms of restoration and rural housing. If we consider that a hiker can go 4 km in 1 hour, this means that, in Sector 3 on Via Algarviana between Vaqueiros and Furnazinhas, each person will walk for about 20 minutes with the setting for a busy landscape just with solar panels, which of course have a very high negative impact on Portuguese and foreign users of the Via Algarviana who come looking for natural or semi-natural landscapes and not profoundly altered landscapes.

So there is a strong possibility that many of the Via Algarviana users choose not to undertake this sector, with very negative consequences for the region's economy.

On the other hand, a change of route would imply the immediate obsolescence of existing promotional media, in particular the second edition of the Guide, recently published with a circulation of 10,000 copies.

Compensatory measures

The project concerned would contribute effectively to increase the weight of the solar component in the production of electricity in our country, covering about 17% of the total consumption of the Algarve power. Nothing, however, that could not be done by a dozen solar power plants of small and medium-scale, scattered throughout the territory and deployed in peri-urban or agricultural areas abandoned.

However, with respect to carbon accounting, many questions arise about the actual balance of this project. On the one hand, they present data on reduction of emissions of greenhouse gases by power generation of solar origin. But absolutely nothing is said in the EIA about the very significant reduction in the derived carbon sequestration from complete destruction of vegetation on 600 hectares in order to be able to assess accurately the impact of this project in the fight against climate change.

As for the socio-economic aspects, the project involves investment of 200 to 220 million euros (conflicting data depending on the point of the EIA concerned), largely to pay for imported equipment. It envisages the creation 300-600 jobs, but only temporary during parts of the year and a half of construction. After that, they would remain 22-35 permanent jobs (conflicting data depending on the point in question EIA) related mainly to specialized staff who have for the most part, to be hired out of Alcoutim region.

Direct compensation proposed by the promoter are ridiculously meager given the size of the project, possibly due to underlying desire to withdraw hence the maximum profit.

One such compensation relates to the lavender plantation between the lines of tables deployment of photovoltaic panels, associated with the production of essential oils and deployment of hives for honey production. First it is doubtful that the rosemary farm for the production of essential oils may be feasible, since, in rainfed conditions, its regeneration will be very problematic. As for the maintenance and management of hives in a completely artificialized context such as this project, nothing is referred to by the EIA.

Other compensation includes restocking of about 70 ha, the remaining area belonging to the promoter with indigenous tree species (especially Quercus). As mentioned, the area of pure and mixed stands of oaks and cork trees to destroy is about 250 ha, which fully demonstrates the failure of this measure.

It should be noted that the total area owned by the developer and not affected directly by the solar plant equipment reaches about 760 ha. Care for understand what the actual destination that the prosecutor intends to give in the future to these hundreds of remaining hectares: creation of a nature reserve with regeneration of native vegetation and promotion of sustainable forest management or, on the contrary, expansion of the solar plant or recovery Old tourism project of Finca floor cloths (hotels, golf, hunting)?

On the other hand, it does not propose any compensatory measure for the destruction of the surrounding scenery of the Castle of Santa Justa. At least it would be logical to present a cleaning plan and recovery of this important archaeological site, providing it with conditions to be properly publicized and visited.

Also in the case of Via Algarviana, it does not appear any measures to minimize or offset the negative impact of the project.

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