Renewable Energy and Conservation Policy Recommendations for Chile

Program on Conservation and Innovation at the Harvard Forest

Marc Ackermann

Kevin Fink Erik Jensen Maria Krug

December 12th, 2013

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Table of Contents Executive Summary .......................................................................................................................2

Introduction ....................................................................................................................................6

Policy Recommendations.............................................................................................................11

Drive Conservation Focus into Policy .......................................................................................11

Improve Permitting Efficiency ...................................................................................................16

Emphasize Social Inclusion .......................................................................................................23

Increase Agency Collaboration ..................................................................................................28

Sustain Impact with Measurement and Enforcement .................................................................34

Conclusion ....................................................................................................................................38

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EXECUTIVE SUMMARY AND KEY RECOMMENDATIONS

As Chile continues to experience rapid economic growth, energy production limitations have

become  one  of  the  country’s  greatest  obstacles  as  it  pursues further development. Current energy

generation relies on fossil fuels, large-scale hydropower, and imported energy. To decrease this

dependence, the government has committed to an unprecedented shift towards non-conventional

renewable energy sources (NCREs). With this transition, Chile has the opportunity to become an

international leader in renewable energy development, especially if these projects can be

completed with minimal adverse effects to the environment. As the global community enters into

increasing dialogue around sustainability and conservation, Chile is in the perfect place to

emerge as a model for policy which promotes environmentally conscious project development

and implementation.

To capitalize on these opportunities, the Chilean government must shift the focus of renewable

energy policy. The following analysis provides five policy recommendations to direct dialogue

around policy changes. The recommendations include driving conservation focus into policy,

improving permitting efficiency, emphasizing social inclusion, increasing agency collaboration,

and sustaining impact with measurement and enforcement. In order to meet energy goals and set

the stage for environmentally conscious NCRE development, the Chilean government must

incorporate these recommendations into policy.

Drive Conservation Focus into Policy

In order to drive conservation focus into policy, energy project siting must be used to mitigate

environmental impact. The United States Bureau of Land Management (BLM) was used as a

model for conservation in renewable energy policies and processes for its similarity to the

Northern Region of Chile. The analysis of the BLM provides insight in certain areas of attention

where  Chile’s  conservation policy can improve. First, Chilean policy must provide a strategy for

proposed projects with unavoidable environmental damage. Second, increased emphasis must be

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placed on protecting biodiversity in the Atacama Desert, with a special  focus  on  the  region’s  

water sources. Finally, the ways in which individual projects are evaluated for environmental

impact must be reconsidered to improve efficiency and thoroughness. Implementing these three

policy recommendations ensures that the  natural  resources  of  Chile’s  Northern Region are

conserved  for  the  country’s  future.  

Improve Permitting Efficiency

The potential for renewable energy generation in Chile remains largely untapped due to an

inability to efficiently move projects through the permitting process. Using the United States

Bureau of Land Management (BLM) as a model, policy recommendations were formulated in

order to perform thorough environmental assessments within the 150 day period, shortened from

700 days  for  Chile’s  Servicio de Evaluación Ambiental (SEA). Currently, the SEA requires each

company applying for an environmental permit to provide the comprehensive impact study of the

site. Moving forward, the Chilean government must establish an agency tasked with the most

suitable regions within the country for specific types of NCRE projects. This change would

significantly reduce the demands placed on private companies as they apply for permit.

Additionally,  the  SEA’s  freedom  to  request  an  unlimited  amount of application revisions, which

each allow four additional months for review, significantly reduces the likelihood of an efficient

permitting process. To limit the need for multiple revisions, pre-application meetings should

occur before a proposal is submitted to address site-specific constraints and ensure the site is best

suited for the project. Implementing these changes will help achieve  Chile’s  goal  of  a  faster  

permitting process without sacrificing the integrity and conservation of the permit process.

Emphasize Social Inclusion

Chile’s  current  efforts  to  substantially  increase  its  NCRE  production  lack  sufficient  emphasis  on  

social inclusion. In order to successfully develop large infrastructure for energy production in

Northern Chile, permitting agencies and private energy companies must actively seek public

input  and  demonstrate  the  country’s  commitment  to  working  with  local  communities.  Failure to

engage local communities prior to permit approval has severe consequences, namely public

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protests and lawsuits. Chilean policy, therefore, must require local communities to be included in

the development stages of proposed projects, offering insight into site location, environmental

impact concerns, and potential compensatory measures. Second, the Chilean government must

recognize the potential for job growth in energy production and environmental conservation,

while also committing to keeping these jobs inside local communities. By engaging the public

throughout the process of NCRE development in Northern Chile and providing jobs in

economically depleted areas, Chile can serve as a global leader regarding social inclusion in

renewable energy development.

Increase Agency Collaboration

With inefficient inter-agency collaboration and minimal frameworks for cross-sector interaction,

two initiatives for high level governmental policy making are vital for Chile to become a leader

in conservation and renewable energy. By developing a more holistic approach to inter-

governmental focus on conservation strategy and developing strategic partnerships across a

variety of sectors, Chile can grow sustainably with a new conservation policy. To capitalize on

inter-governmental inefficiencies, the CER, the organization in charge of renewable energy,

needs to restructure and refocus its approach by driving change in three key areas: focusing on

national policy, increasing stakeholder participation, and creating direct involvement with

Chilean public. Cross-sector collaboration will advance the cause of the renewable energy policy

by integrating a wide variety of groups through partnerships and a national-convention. Within

these two areas, Chilean policy can become more comprehensive through a multi-stakeholder

approach that eliminates waste in processes.

Sustain Impact through Measurement and Enforcement

The final component of the policy recommendation must focus on the impact and effectiveness

after implementation. To do this, two aspects must be considered: the efficiency of the permitting

process and the  achievement  of  the  policy’s  overall  goals.  In  order  to  determine  the  efficiency  of  

the permitting process, a system must be in place to measure the time and cost required to

receive a permit. In addition, there must be consistency between the initial proposal, design, and

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final construction to ensure that companies are held accountable to the environmental footprint

agreed upon in the initial site grant.

Four indicators were developed to measure the progress towards the overall goal of renewable

energy production and conservation: the natural asset base, environmental productivity,

environmental quality of life, and socio-economic context. Analysis of these indicators will

require sustained monitoring of each project, both during the initial siting procedures and

throughout the life span of the project. Finally, the success of this policy depends on clarity in

expectations of compliance and consequences of non-compliance. This will require frequent

inspections to ensure that the agreed mitigation and compensatory mitigation strategies are being

followed. Ultimately, this strategy of measuring the policy impact holds all parties accountable.

Key Recommendations The government of Chile should:

Continue to push conservation as an important component of renewable energy

development, particularly throughout the permitting and siting processes

Improve the permitting process to be faster and more efficient while still promoting

thorough environmental assessments of each project

Increase efforts to engage the public and actively seek feedback from the public

throughout the entire process of approving renewable energy projects

Create an overhead national agency to implement this policy that incorporates

stakeholders from different government organizations as well as the private and non-

profit sector

Develop a strategy for measuring the impact of this policy after implementation to

determine effectiveness and inform policy changes

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1. Introduction

Context

In order to continue its sustained economic growth, Chile must overcome the current obstacles it

faces regarding energy production. Chile has recently experienced tension between neighboring

countries over gas exports as well as transmission, which promotes the benefits of meeting

current energy needs domestically. Furthermore, international trade places increasingly more

pressure on renewable energy sources. Under this pressure, attention shifts towards conservation

in order to promote renewable energy development projects. As seen below, in 2011, 61% of

Chile’s  electricity  generation  was  from  fossil  fuels,  33%  from  large-scale hydro power, and less

than 1% from wind power (USA 2013b). This presents an opportunity for Chile to lead Latin

America in renewable energy power generation.

The opportunity for renewable energy generation is vast in the Northern Region of Chile; the

Atacama Desert provides a landscape which can support renewable technologies, especially wind

and solar. Formed over millions of years of unrelenting sunlight, the desert is a proven source.

Fossil Fuels 38.3 (61%)

Wind 0.3 (1%)

Hydroelectric 20.8 (33%)

Biomass 3.4 (5%)

Renewables 24.5 (39%)

Chilean Electricity Generation 2011 Source: US Energy Information

Administration (in billion kilowatthours)

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Chile, as a coastal nation, benefits from its proximity to the Pacific Ocean, where cold currents

cool the hot desert air, producing an endless supply of wind. For many reasons, Chile has the

opportunity to generate a sustainable supply of renewable energy which also has conservation at

its forefront.

Recent policy changes in Chile illustrate the value the Chilean administration places on

renewable energy sources and the pressure the country is feeling to rapidly expand its NCRE

capacity. On October 14, 2013, the Chilean government enacted a law requiring utility

companies to acquire 20% of their total electricity from non-conventional renewable energy

sources by the year 2025. This target presents an immense challenge for Chile and demands a

large amount of new energy plants to be planned, constructed, and made operational in the next

ten years. As the Chilean government has placed added emphasis on creating these new energy

sources with great speed, it has increased the risk that energy projects will be approved before

the environmental impact is fully understood and local populations have been consulted. Moving

forward, therefore, it is crucial that Chilean policy balances the desire for rapid site creation with

the need to protect the Chilean people and the environment. If Chile can implement policy that

will encourage alternative energy development while at the same time mitigating environmental

impact, Chile can serve as a model in the international community in navigating this area. By

putting conservation at the forefront of this renewable energy issue, there are enormous benefits

for Chile, both internationally and domestically.

Potential Impact of Policy Change

International Impact As the conclusion of the timeline for the Millennium Development Goals (MDGs) approaches in

2015, there is discussion around the next generation of development, the Sustainable

Development Goals (SDGs). Whereas the Millennium Development Goals were fairly simple

and concise, ongoing negotiations around the SDGs are focusing on broader and more complex

issues. The MDGs focused mainly on social development, and the SDGs are including a more

comprehensive view, including economic, social, and environmental aspects. Therefore, some of

the issues at the heart of the SDGs will be climate change, environmental sustainability, and

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economic inequality. Given the scope of these issues, the SDGs will require more participation

from all countries, both developed and developing which contrasts with the MDGs where for the

most part, developed countries were making recommendations only for developing countries

(IRF 2013 and Sean Long, presentation, October 16, 2013). The Sustainable Development Goals

will be implemented in 2016, which means Chile has the opportunity to begin developing policy

to  address  these  issues  at  the  same  time.  The  proposed  policy  recommendations  for  Chile’s  

renewable energy development address issues of conservation and environmental sustainability,

as well as have the potential to address economic inequality both in an international and

domestic context. With this policy as part of its strategy, Chile could participate in the

negotiations around the SDGs and emerge as an influential player in meeting the goals after their

implementation in 2016.

Domestic Impact

In  addition  to  promoting  Chile’s  interest  internationally,  this  new  renewable  energy  policy  has  

the  potential  to  improve  Chile’s  domestic  concerns  both  in  the  public  and  private  sectors.  As  the

government has made renewable energy development a priority, they have the potential to gain

much from doing so with an additional focus on conservation. There is clear outcry from the

general public concerning the environmental impacts surrounding renewable energy projects, as

seen in the protests against the proposed HidroAysen dam. Despite these protests, the

government approved the project but continues to face opposition. The two main companies

involved  with  the  project  have  “both  publicly  stated  that they will only move forward with the

project  if  there  is  political  and  public  agreement  within  Chile”  (Ross  2013).  The  proposed  policy  

recommendations will pursue ways to avoid this problem with future renewable projects by

incorporating more stakeholder inclusion and transparency in the permitting process, which was

one of the main public concerns in the HidroAysen dam project. The continuation of the

HidroAysen project is also contingent on upcoming presidential elections, as the front runner

candidate Michelle Bachelet has stated that she is against the project and plans to pursue

alternatives in renewable energy technology (Ross 2013). This conservation focused policy

provides an opportunity for the new administration to develop these alternatives in a way that

will  encourage  the  public’s  support.

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As seen in the HidroAysen example, companies also face high risk when their projects are

opposed so heavily by the public. There is also much to gain, therefore, for the private sector by

putting more emphasis on conservation. Additionally, companies hoping to invest in renewable

energy projects will benefit from having a streamlined and more efficient permitting process, so

they do not waste time or financial resources. There is a clear market for renewable energy in

Chile that could provide enormous economic gains for companies that develop responsibly and

in collaboration with both the public and the government. Both private companies and

government agencies, therefore, are incredibly motivated to ensure environmental conservation

and  engage  local  populations  throughout  this  effort  to  dramatically  increase  Chile’s  NCRE  

capacity. To achieve their goals efficiently, the Chilean government must provide a framework

for project development that incorporates sustainable conservation and public inclusion.

Strategy

To develop new policy for conservation focused renewable energy development,

recommendations focused on sustainability and implementation. The two opportunities that

address sustainability are a multi-stakeholder approach and ingraining accountability into the

policy. The focus on implementation will address operational challenges leading to efficient and

optimized processes. To do this, the policy will focus on driving conservation focus into policy

and attacking permitting process inefficiencies. As delineated in the issue tree below, by

focusing on these opportunities, policy makers can help guide Chile toward successfully

reaching the 2025 goal.

Opportunities

Sustainability

Accountability Multi-

Stakeholder Approach

Implementation

Conservation’s  Role in Policy

Process Inefficiencies

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Sustainability Sustainability of this policy is dependent on a multi-stakeholder approach. Without sufficiently

addressing major concerns from differing factions, a policy cannot be comprehensive and

successful. It is imperative that this approach includes public opinion and is adopted fully by

those it directly impacts. Thus, it is very important to include all relevant stakeholders in the

process. Having multiple views on a position will inevitably optimize the outcome.

Additionally, accountability will impact policy sustainability  through  a  group’s  unwavering  

commitment to executing the strategy. By having a group that is held accountable, they must be

dedicated and incentivized toward making change happen in renewable energy policy. Especially

important in fostering accountability is a measurable and enforceable framework for evaluating

change.

Implementation One crucial element of the policy recommendations focuses on including a conservation focus in

all initiatives to drive sustainable  use  of  the  country’s  scarce  resources  and  habitats.  An  

environmentalist approach has additional benefits deriving from an economic, social, and

political standpoint.

Additionally, the elimination of process inefficiencies will drive a conservation focused Chilean

renewable energy policy down a path of rapid improvement. Incorporating continuous

improvement by focusing on eliminating waste, the Chilean economy will benefit largely from

close attention to processes such as permitting and policy making. Additionally, the change will

be pushed to happen quicker, while maintaining the same high standards.

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2. Policy Recommendations Drive Conservation Focus into Policy

Chilean energy policy must ensure that the natural  resources  of  the  country’s  Northern  Deserts

are protected as NCRE projects become more prevalent. Current energy policy in Chile

illustrates the country’s  commitment  to  providing  environmentally  sustainable  solutions.  

Renewable energy projects, however, present a complex and largely varying array of

environmental concerns that make ensuring natural resource conservation a formidable

challenge. One of the primary concerns facing Chile is addressing potential energy projects in

which environmental harm is unavoidable. In order to decide how energy projects can be

allowed to move forward if certain environmental damages are anticipated, a case study from a

Chilean company, Enel Green Power, will be used to explore the role of compensatory

mitigation. Additionally, an increased emphasis must be placed on water usage and biodiversity

with  Chile’s  Northern  Desert  Regions. Finally, measurement tools must be in place to evaluate

the environmental effects of each individual energy project. The current procedures used by the

United States Bureau of Land Management provide tremendous insight into the ways individual

projects can be evaluated. By requiring compensatory rehabilitation actions, protecting the

desert’s  water  sources,  and  evaluating  the  environmental  impact  of  each project, Chilean policy

can ensure that the  natural  resources  of  Chile’s  Northern  Region are conserved.

Current Conservation Initiatives in Chile

The Chilean Government has demonstrated an understanding of the importance associated with

environment conservation. This focus is most notably seen in the establishment of the National

Environment  Commission  (CONAMA),  which  reported  directly  to  the  President’s  office  through  

the Ministry General Secretariat of the Presidency. CONAMA functioned as a public body and

decentralized environmental services. In 2010, CONAMA was replaced by the Ministry of

Environment  due  to  Chile’s  ascension  to  the  Organization  for  Economic  Cooperation  and  

Development (OECD). This reinforced the need for corporate environmental responsibility due

to the pressures on industries exporting to OECD countries. These export-oriented concerns have

driven environmental progress in Chile.

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Successes are evident in trials which have already been performed in Chile. In December 2010,

the Ministry of National Assets, in collaboration with the Ministry of Energy, opened up an

international tender for public lands in the Northern Region. The invitation made sites in the

Atacama Desert available for wind energy projects. The sites were screened for proximity to

transport infrastructure and transmission lines as well as resource access, with measurements

indicating average and adequate wind speeds. Companies presented proposals for wind farms

with capacities between 40 and 100 MW for a single site. The winning proposal was granted a

land-use concession for 25 years for the implementation of the project (Sciaudone 2012). The

tender was granted to Enel Green Power Chile (EGP), a green power development company

based in Italy. Following the award, feasibility studies and an environmental impact assessment

were performed before the company began construction of the 99 MW project containing 33

wind turbines. Once in operation, the Taltal wind farm will generate over 300 GWh per year,

preventing the emission of 200,000 tons of CO each year and meeting the consumption needs of

170,000 Chilean households (EGP 2013). To support the project, a 20-year power purchase

agreement (PPA) was enacted and will ensure power transmission to the Chilean Central Region

transmission network (SIC), through a substation 50 km away from the wind farm.

EGP also represents a model for compensatory mitigation in Chile. The company has

demonstrated a high level of social responsibility and seeks to assist local communities which

may be impacted negatively from renewable energy development projects. EGP established

programs aimed to assist local communities, such as rural electrification, scholarship, and health

and agricultural programs (EGP 2011).  The  company’s  agricultural  program  provides  support  to  

indigenous communities, such as the Mapuche, located near the EGP small hydroplant of

Panguipulli. The Mapuche have been largely marginalized by development, and show a high

poverty  rate  close  to  EGP’s  plant  with  low  nutrition  and  education  levels.  The  company  founded  

a program to construct greenhouses, offer technical assistance, provide funds for seeds, and

support sales of produce for the Mapuche. Farmers in this program are now selling their organic

products to UNIMARC, the largest network of supermarkets in Chile (Mapuche 2011). Though

the tender did not specifically require compensatory mitigation, the actions taken by EGP to

catalyze social change illustrate the benefits of compensatory actions.

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The tender leading to this project was the first Chilean public tender jointly organized by the

Ministry of National Assets and the Ministry of Energy. Its aim was to promote renewable

energy development and energy dependence, and it certainly did. However, the tender was slow

to attract developers due to perceptions that the concession was too risky and expensive.

Furthermore, the ministry undertook five tender modifications in order to attract companies

(Sciaudone 2012). Many were hesitant because the concession was only for the site;

environmental approval and a PPA needed to be obtained. This segmentation added risk for

many companies.

Biodiversity and Water Resources

To combat this segmentation, land-use planning needs to specify where renewable energy

projects can be built. A major hindrance of this is water usage. Currently, water rules are widely

seen as favorable  to  the  mining  industry,  and  as  a  form  of  privatizing  water.  According  to  Chile’s  

Water Code, mining companies have the right to use any water found during their work (Ulmer

2013). Especially following a series of droughts, the water code must be reviewed for rights. The

state must first guarantee water for human use, and also for small-scale production, such as

farming. In light of the mining boom in Chile, it is now necessary to review how profits are used

to protect the environment. Biodiversity is dependent on water quality, for as soon as water

quality diminishes, biodiversity suffers. Future environmental efforts must focus on how land-

use impacts water resources, and therefore conservation of biodiversity. The desert is the most

resource scarce type of environment on the planet; therefore, the competition for those resources

is fragile. Any flux in resource distribution has the potential to devastate biodiversity and

therefore the entire region. Because this balance is so pivotal, environmental concern must be

prevalent at every stage of a project, beginning with water.

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Using the BLM as a Model for Improvement

To ensure that environmental concern is prevalent, the BLM has integrated the National

Environmental Policy Act (NEPA) as a part of the project process. NEPA requires all federal

agencies to incorporate environmental concerns into decision making process in regards to the

environmental impacts of all proposed actions and any reasonable alternative to those actions

(USA 2009). Through this,  a  preliminary  screening  must  be  performed  for  NEPA’s  applicability  

for each land parcel. Then the organization must prepare an Environmental Assessment (EA) to

determine whether an Environmental Impact Statement (EIS) is require, and if so, the EIS must

be prepared in order to determine if an action may significantly affect the quality of the

environment. Each assessment must also develop a strategy for public involvement. A common

risk for many projects is risk of habitat loss. Many local groups have asked for NEPA

assessments in order to ensure environmental considerations of a proposed action. Furthermore,

alternatives must be defined and analyzed as a part of the assessment. This process allows for

community engagement and stakeholder participation.

1 Hydroelectric Energy Picture from Instituto de Ecología Política

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Conclusion

The Chilean Government’s  concern  for  protecting  the  country’s  natural  environment  has  been  

well illustrated by their efforts to promote environmental sustainability through their current

energy policy. As Chile prepares for a dramatic ten year push towards renewable energy,

however, it must not sacrifice environmental conservation for large quantities of renewable

energy  sources.  In  order  to  maintain  and  improve  upon  Chile’s  current  conservation  policies,  

Chile must require companies to perform environmental improvement campaigns alongside

community members as compensation for environmental damages, create policy protecting the

region’s  water  sources,  and  strengthen  its  environmental  assessments  of  individual  projects.  

These three policy recommendations help ensure that the natural resources of the Atacama

Desert will be available to the local people for generations to come.

Key Recommendations The government of Chile should:

Include conservation and biodiversity in siting

Ensure compensatory mitigation over project lifespan

Restructure water rights for effective resource allocation

Involve all stakeholders in environmental impact

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Improve Permitting Efficiency

Despite the large potential for wind and solar power generation in Chile, these resources have

largely remained untapped. Currently, the capacity of solar plants that are operational or under

construction  represent  only  1.78%  of  the  country’s  solar  power  potential,  and  the  existing  wind  

farms achieve a mere 0.78% of the countries wind power potential (von Hatzfeldt 2013). This

failure  to  utilize  Chile’s  capacity  for  NCREs  is  not  a  result  of  insufficient  project  proposals,  but  

rather an inability to efficiently move projects from conception to reality. According to the

Chile’s  2012 energy strategy, more than 90% of proposed NCRE projects have yet to reach the

construction stage. One of the primary causes of the significant delays associated with renewable

energy  projects  is  the  application  for  permit  through  Chile’s  Servicio de Evaluación Ambiental

(SEA), which performs an environmental impact assessment on every proposed energy project.

The Chilean Government recognized the significant delays associated with the permit review

process and in response, enacted the Law on Electricity Concessions in October of 2013 limiting

the allowable time for permit review to 150 days. While this law addresses the need for more

efficient  permitting,  it  threatens  the  SEA’s  ability  to  provide  sufficient  environmental  

assessments. The United States Bureau of Land Management provides a model for a streamlined

permitting process that incorporates thorough environmental assessments but also decreases the

time needed to permit. By  following  the  BLM’s  example,  the  SEA’s  environmental  assessments  

can be performed within the new 150 day limit while still adequately identifying environmental

risks.

Current Chilean Permitting Policy

As the first step for companies or organizations applying for environmental permit, the SEA

requires the company to provide an environmental impact study that describes, in depth, the

predicted environmental impacts of the project in question, the countermeasures the company

plans to take to limit the impact, and substantial due diligence meant to demonstrate a complete

understanding of the potential effects of the project. In order for an environmental impact study

to be accepted for review by the SEA, the company must first prove that the project does not

pose any significant health risks, negatively affect the quality or quantity of renewable resources

such as soil and water, displace populations, impose on protected lands, or present a potential

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decrease in tourist activity. If these qualifications are met, the SEA initiates the review process

by sending the impact study to all related state and local agencies. The agencies then have 120

days to review the impact study and request changes or additions (Maxwell 2009). After this

period has elapsed the agencies involved vote to decide whether the proposal is approved,

denied, or sent  back  to  the  company  with  all  of  the  agencies’  requested  clarifications,  

corrections, and additions. If the agencies vote to send the assessment back for revision, the

company then submits a revised version that is once again circulated to the relevant agencies,

and the process continues in this manner until the agencies are satisfied with the impact

assessment. Importantly, all impact studies are available to the public, and the SEA accepts

comments from any individual or group concerned about the effects of the project. If at any point

the agencies vote to approve the project, the SEA issues a Resolucion de Calificación Ambiental

(RCA) that formally allows the company to proceed with construction.

The SEA project approval process has been suggested to favor the companies proposing projects

by limiting the time government agencies have to review proposals while giving companies

unlimited time to make changes to their proposals. Despite these arguments that the SEA is

tailored to push development projects through the permit process, many projects have

experienced the opposite effect. One such project, Sarco Windfarm, applied for SEA approval in

October of 2012 and just received its third round of clarification and correction requests from the

involved government agencies. The project would create 95 wind turbines that together would

generate 240 megawatts of electricity, more than doubling the countries wind power capacity.

Instead, the company has spent more than a year applying and reapplying for permit, submitting

a revised version of their proposal and waiting helplessly through four months of review.

Admittedly, wind turbines possess the greatest environmental effects among NCREs, largely due

to the dangers wind farms present for flying wildlife, and many of the additions requested by the

government agencies represent legitimate concerns. If energy projects such as Sarco Windfarm

continue to face permit processes that take years to complete, however, Chile seems unlikely to

reach its 2025 goal.

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Bureau of Land Management Permitting Policy In order to address the inefficiencies presented by the current permitting policy, the Bureau of

Land Management (BLM) in the United States was used as an example to streamline the process

without losing focus on environmental sustainability. First, the BLM conducts thorough analysis

in order to identify sites with high potential for renewable energy development without causing

adverse environmental effects. To do this, the BLM focuses on criteria using Geographic

Information System (GIS) data.

Siting For solar energy projects, one important criterion is land with a solar resource of at least five

kWh/m /day of direct sunlight. Additionally, land slope is considered to find sites with a

maximum of five percent grading and ideally less than one percent grading over a site. Next,

transmission access is examined in order to utilize existing infrastructure and limit the

environmental impact and costs associated with expanding current transmission grids. Sites need

to have transmission access within 50 miles as well as available capacity (69-345 kV). In order

to optimize public land efforts, a land parcel is required to be at least 40 acres in area. This is due

to the infrastructure and project demands for solar projects, which require a certain scale in order

to prove feasible. The final screening criterion is access to roads or rail within 50 miles. The

BLM maintains that other identification factors are important in evaluating potential for

renewable energy projects, but are limiting to a lesser extent. These site factors include water

resource availability, removal of vegetation, location within 25 miles of a main natural gas

pipeline, policy support, livestock protection possible, and location within 100 miles of a

population center.

Similarly, criteria for wind projects include wind potential, with sites needing to demonstrate

winds in Class 4 and above for short term winds, and Class 3 and above for long term winds,

transmission access within 25 miles with available capacity, access to roads within 50 miles, a

parcel size of ten square miles at best, and an optimal elevation of 3,000 to 4,500 feet.

Additionally, compatibility with wind energy development is analyzed, which considers social

response and eliminates sites in view of scenic areas, view-shed, and non-developmental regions.

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Application Process Once these zones have been sited, companies then go through a standardized application process

to obtain approval for use of the land, consisting of pre application screening, Right of Way

approval, Plan of Development approval, and Environmental Assessments. Before any

application is submitted, a company interested in developing on BLM land must first participate

in two meetings with the BLM and the primary stakeholders in the project; typically other

federal agencies, tribal governments, state and local governments, and local communities. These

early meetings serve to identify site specific constraints, ensure that appropriate technology has

been selected, and consider alternative sites. These meetings are meant to occur before

significant work has been done on the project design so that the company would be open to

changes in the proposal to decrease negative environmental effects (BLM 2011a). In addition,

early meetings promote cooperation between all parties involved throughout the entire proposal.

Next, submission of the Right of Way grant shows the BLM that the company has the financial

and technical capacity to construct and operate the facilities. It details  the  organization’s  

experience with utility scale projects, as well as demonstrates the ability to carry out all

environmental studies required. Each Right of Way application requires subsequent submission

of a Plan of Development which includes the proposed technology, location, and infrastructure

required, including detailed design proposals and results of geotechnical and environmental

studies. The Plan of Development provides enough information to begin the environmental

assessment of the project in accordance with the National Environmental Policy Act (NEPA).

Environmental Assessments In its Programmatic Environmental Impact Statement (PEIS) which designated the Solar Energy

Zones (SEZ), the BLM already conducted thorough NEPA environmental assessments of each

zone. Consequently, site-specific environmental assessments can reference the broader study

already completed and only need to focus on environmental issues caused by specific project

details. This eliminates the need for redundant studies and decreases the time for approval since

it does not require an entirely new and separate Environmental Assessment (BLM 2013b). The

submission of the amended Environmental Assessment will lead to Finding of No New

Significant Impact approval as long as any effects caused by the proposed project may be

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reduced through mitigation (BLM 2008). After approval, the project then receives a Notice to

Proceed, which is issued for each phase of construction. No work can begin before the Notice to

Proceed (BLM 2013c).

Incentives To encourage companies to develop utility scale projects, the Bureau of Land Management

offers both logistical and financial incentives. First, the streamlined application process

guarantees faster and easier permitting for projects, while still ensuring thorough environmental

analysis. In addition, by working with the BLM, companies will have access to already

completed mitigation plans specific to that SEZ, which further promotes sustainable

development. Finally, companies receive economic benefits because the initial work done by the

BLM on environmental analysis means the company does not have to pay to conduct the studies.

The BLM also has a ten year phase in period for rental payments and charges a fixed rental

payment for the duration of the lease, which decreases overall costs. Uncertainty is minimized

for the company, as the BLM may provide a 30-year lease (BLM 2013a).

Policy Recommendations for Chile As outlined above, one important reform to the SEA review process must address how to reduce

the length of the process while continuing to serve as an effective identifier of projects with large

potential for negative environmental impact. Firstly, it appears that every company uses the same

template for their impact study, regardless of the type of power plant being proposed. The SEA

needs to develop individual impact study templates for each energy type (ie. wind, solar, etc.)

that take into account the unique environmental concerns associated with each NCRE. These

impact studies could then be used to identify certain zones with resources most efficient for that

energy type without causing significant environmental harm. If companies were then able to

choose from already sited land, it would eliminate much of the unnecessary time spent on

revisions to the environmental assessments. Instead of each company conducting an independent

environmental assessment, an approach similar to the BLM could be taken. If an in-depth

environmental assessment has already been completed, then the company can submit a narrow

amendment which addresses specific issues caused by the project and references the more

comprehensive study.

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Additionally,  the  SEA’s  freedom  to  request  an  unlimited  amount  of  application  revisions  that  

each allows four additional months for review seems to significantly reduce the likelihood of

efficient permit review. This process could be improved significantly by requiring pre-

application meetings before a proposal is submitted to address site-specific constraints and

ensure this site is best suited for the project. Having these meetings before the proposal is

submitted will reduce unnecessary time spent on revisions and will increase the likelihood of

cooperation in implementing changes, since the company will not have already invested

significant time and energy in the proposal. In addition, after the proposal is submitted, the SEA

and relevant government agencies should be restricted to one request for revision and must

approve the revision if the concerns raised are properly addressed to eliminate the uncertainties

surrounding the timeframe of permitting.

Key Recommendations The government of Chile should:

Identify specific areas most conducive to sustainable NCRE development

Perform comprehensive environmental assessments of these sites

Allow individual projects to reference the overall assessment; thus eliminating the need

for a company to perform a new environmental assessment

Require pre-application meetings to limit the review process

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2 2 Inclusive Solar Energy in Chile from Ministry of Energy in Chile

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Emphasize Social Inclusion

The Chilean Government’s  current  energy  policies  fail  to  adequately  engage  local  populations  in  

the planning and implementation of NCRE projects. As previously stated, the Chilean

Government would benefit from launching an initiative to identify specific zones in Northern

Chile that are suitable for the implementation of solar plants, wind farms, and other renewable

energy sources. This process, which would greatly simplify the permit application efforts of

energy companies, also provides the ideal opportunity to promote public participation in the

selection of suitable project locations. Seriously considering public opinion regarding future

projects  is  critical  to  Chile’s  success  in  the NCRE sector. The HidroAysén Dams Project clearly

illustrates the consequences of disregarding public opinion while making decisions concerning

large energy projects. Approving the project in 2011 before launching public outreach programs

has caused two years of lawsuits and protests and marks one of the greatest failures of the Piñera

administration. If an early emphasis had been placed on gauging public opinion regarding

HidroAysén, the Chilean Government could have identified dam locations more conscious of the

environment and more preferable to local populations. At the very least, years of investment

could have been avoided. Moving forward, social inclusion must play a substantial role in the

selection of sites for energy projects.

BLM Model of Community Engagement Again, the BLM provides a good example of engaging communities throughout the zoning

process. In 2008, the BLM began an effort to identify regions in the southwest that are well-

suited for solar energy plants. After site identification, the contributing agencies launched a

period of public scoping which included public meetings in every city in close proximity to the

proposed zones. Additionally, the program invited Federal and State agencies, Native American

tribes, relevant organizations, and members of the public to send comments regarding the

possibility of solar energy facilities in the region. Meetings were also held, and the public was

invited to submit comments, after the preliminary draft of zones, the supplemental draft of zones,

and preceding the release of the final zoning decisions (BLM, 2013d). Throughout the process,

the US Solar Energy Program kept the public informed and sought public opinions. This ensured

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that when final decisions were made, neither the government nor the public were surprised. By

making an early and sustained commitment to social inclusion, the US Solar Energy Program

knew that it had public support and that its efforts had no risk of being wasted due to unexpected

public protests.

Emphasis on Public Opinion in Chile

Chile’s  newly  enacted  Law  on  Electricity  Concessions  has  the  potential  to  overlook  public  

opinion as emphasis is placed on shortening the permit process. For this reason, Chilean Policy

must take an aggressive approach to community engagement, implementing programs that

require the active procurement of public opinion regarding energy projects. If the Chilean

Government chooses to launch a zoning project in Northern Chile to identify suitable sites for

NCRE projects, the perfect arena for public outreach is provided. Public meetings with local

towns would allow the Chilean Government to acquire much needed information regarding

public openness for new energy projects in local areas and would demonstrate administration

commitment to collaborating. This would play a large role in repairing the governmental damage

caused by the HidroAysén project. Additionally, with the 80% decrease in permitting time,

surveying the public must be eliminated from the permit review process and, rather, be a

prerequisite for permit application. Chilean policy must require companies to engage the

communities near their proposed project sites before permit applications. Town meetings would

allow the company to introduce its project, outline the economic and environmental impact, and

listen  to  the  community’s  feedback  and  concerns.  Furthermore,  the  Chilean  Government would

significantly reduce the amount of unanticipated public protests and would become a model for

social inclusion within energy projects.

Job Creation

In addition to seeking public opinion, the Chilean Government must acknowledge and seize the

opportunity to use the push towards renewable energy sources as a catalyst for social change.

The Atacama Desert, the region most specifically targeted for future energy projects, contains a

large  indigenous  population  that  has  not  experienced  the  benefits  of  Chile’s  sustained  economic  

growth over the last two decades. The development of NCRE power plants in Northern Chile

offers local populations an avenue towards economic development through substantial job

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growth.  Two  arenas  exist  within  Chile’s  efforts  to  create  an  environmentally  conscious  NCRE  

program that will require the creation of local jobs. Firstly, despite  Chile’s  current  reliance  on  

international manufacturing for solar plants and wind farms, other aspects of these types of

energy projects require locally available labor. Secondly, the Chilean Government’s  attempts  to  

ensure environmental conservation throughout the lifespan of NCRE plants will undoubtedly

require substantial manpower. Most importantly, these two job sources provide job opportunities

to local indigenous peoples with minimal training. The Chilean Government, therefore, must

take advantage of this opportunity to create a better future for the communities of Northern Chile

and create policy requiring these jobs be fulfilled by local people.

Emphasis on Local Economy Numerous jobs associated with NCRE development require local workers. Solar plant and wind

farm projects in the Atacama Desert require expanded access. Road construction, therefore, will

play a large role in the zoning process and the planning stages of individual projects. For timely

construction to occur, the construction crews must be local for each project. Road construction

and other aspects of site allow locally available manpower to be utilized. Additionally, while

manufacturing is performed internationally and installation requires technical expertise,

operations and maintenance jobs must be filled locally. Admittedly, research demonstrates that

wind farms are largely self-sustaining and require limited workers for operations and up-keep.

According to projections made by the United States National Renewable Energy Lab, wind

farms in the United States average one maintenance employee for every 12-15 wind turbines

(Stop 2012). Solar plants, however, present a different story, where thirteen installation and

maintenance jobs can be expected for every twenty manufacturing jobs, according to a study

conducted by the University of California Berkeley (Ban-Weiss 2004). For these jobs in

construction, installation, and maintenance, energy companies must choose between hiring

members of the local population or importing workforce. The Chilean Government must ensure

that these jobs are given to members of the local community through policy. This commitment to

local communities will improve the indigenous quality of life and increase support of local

energy projects.

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Job Creation in Conservation Finally, environment conservation remains a core objective for new policy regarding NCRE

development. In order to achieve this goal, when energy projects are anticipated to negatively

impact the environment, companies will be asked to perform environmental rehabilitation

projects in the region to compensate for the damages the project will bring. These projects

provide another clear avenue for unskilled job growth. By incorporating members of the local

community in the efforts to restore the environment, the Chilean Government will not only

provide these people with a source of income, but will increase their environmental

consciousness. While the majority of jobs available to the people of Northern Chile will be

directly related to energy projects, the potential jobs in conservation cannot be overlooked. The

Chilean Government should strive to keep these jobs within the local communities of the

Atacama Desert region.

Conclusion

Chile’s  rapid  expansion  of  NCRE  production  provides  a  crucial  opportunity  to  demonstrate  the  

government’s  ability  and  desire  to  work  with  the  people.  Past  mistakes  illustrate  the  importance  

of including the public early and often in discussions regarding the construction of future energy

facilities. The Chilean Government must begin this effort by incorporating public opinion into its

zoning process through town meetings in every community close to a given project.

Additionally, Chilean policy must require energy companies to perform their own public forums

in impacted towns before being eligible to apply for permit through the SEA. This ensures that

even  with  the  recent  enactment  of  the  Law  on  Electricity  Concessions,  the  public’s  voice  will  be  

heard before permit approval. Finally, the Chilean Government must recognize the potential for

job growth in energy production and environment conservation, and commit to keeping these

jobs inside local communities. This strategy will not only stimulate local economies, but will

also improve public opinion regarding energy projects. By engaging the public throughout

NCRE development in Northern Chile and providing jobs in economically depleted areas, Chile

will serve as a global leader for social inclusion in renewable energy development.

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Key Recommendations The government of Chile should:

Include local community in the zoning process through town meetings

Require energy companies to perform their own public forums in community

Focus on local job growth creation for redistributing wealth to Northern Chile

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Increase Agency Collaboration

Two initiatives for high level governmental policy making are vital to implement the proposed

changes. By developing a more holistic approach to inter-governmental focus on conservation

strategy and developing strategic partnerships across a variety of sectors, Chile can grow

sustainably with a new conservation policy. These initiatives will address the necessity for a

multi-stakeholder approach to develop a long-term approach to conservation and renewable

energy. Additionally, these recommendations fit closely with addressing other opportunities for

policy improvement by ingraining accountability, adding strength to conservation policy, and

driving out process inefficiencies.

Improved Agency Collaboration

First, a key to advancing a fully evaluative and comprehensive policy for Chile is to follow the

direction of previous initiatives in America and Cambodia of improved cross agency

collaboration. With current frameworks in place, the cross agency approach will focus on a

restructuring  of  an  existing  platform,  the  Centro  de  Energías  Renovables  (“CER”),  to  include  all  

relevant policymakers and address the needs of the citizens.

Develop Strategic Partnerships The second key for Chilean policy makers is to develop strategic partnerships with the public,

non-profit, and private sector to share the weight of implementation, and create access to other

resources. One entity cannot sufficiently address all areas of concern. Thus, developing strategic

Mission: Ensure optimal participation of NCRE sources in Chile's energy matrix, and to contribute to sustainable development.

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partnerships with local governments, conservation groups, various NGOs, and the private sector

will provide substantial benefits for successful policy implementation and execution. Together,

these initiatives will help drive Chile to reaching the 2025 goals in a sustainable and accessible

route.

Non-Optimized Chilean Collaboration From an institutional perspective, Chile does not have optimal interaction and collaboration on

energy policy. While there is currently an inter-ministerial group in the Ministry of Energy, the

CER, the collaboration is often inefficient and less focused on national scale policy.

Additionally,  the  CER  is  primarily  focused  on  “medium  and  small  scale  projects”,  which  are  

important but less directly tied to policy (CER 2013). As a final aside, the constitution has

inherent  limitations  that  have  hindered  some  areas.  An  economist  from  Chile  stated,  “The

Chilean Constitution is read to a strict standard, which requires explicit delineation within the

law to allow action” (Montecinos, personal communication, November 27, 2013). Combined

with a popular push for constitutional rethinking, opposing inter-ministerial viewpoints and CER

focus on non-policy measures, the collaboration inside the government has ample room for

improvement.

Overall, the political landscape in Chile has the opportunity to give rise to a green transformation

in the energy sector. This is due to a public will for constitutional transformation leading to

improved policy making power and the entrance of  a  newly  elected  president.  “A  hot  topic  in  the  

presidential elections is the constitution and its limitations. This will require the new

administration to address the problem” (Montecinos, personal communication, November 27,

2013). The political clout is mounting and a new presidential leader will likely have an enormous

impact on the robustness of policy initiatives, such as the proposed policy changes. With the

2025 target already in place, there is also a necessity to focus deeply on renewable energy and

conservation, especially within the government. There is a perfect storm in place; there is an

enormous opportunity for an incoming president to put their mark on energy and the

environment in Chile.

Addressing the needs of improved non-partisan collaboration, there will be a comparison with

the Cambodian Government as a developing country example and the United States as another

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case. Furthering the debate on partnerships, American policy focused on conservation will

provide an illustration. Additionally, current precedents and frameworks in Chile need to be

addressed to evaluate the feasibility of these recommendations.

Cambodian Inter-Ministerial Green Growth Working Group From another developing nation, the Royal Government of Cambodia has been a leader in

addressing green growth: economic growth that is socially and conservation focused. Similar to

Chile, in the past, Cambodia did not have sufficient coordination between governmental entities.

To combat this communication barrier, the Royal Government of Cambodia established the

Inter-Ministerial Green Growth Working Group (GGWG), representing 19 ministries, to

establish a green growth policy; within a short time horizon, the group successfully designed the

Green Growth Roadmap for Cambodia in 2010 and the National Strategic Plan on Green

Growth. After taking a non-partisan multi-stakeholder approach, this plan incorporates seven

accesses that are carefully tailored to the poor and marginalized communities. For both nations,

the separation of players has hindered policy making. However, Cambodia has made

considerable progress on integrating policy makers through the GGWG. Moving forward, Chile

has an opportunity to follow a similar path to coordinate discussions between policymakers.

Thus, a viable option is to develop a large and integrated cross-party, cross-ministry organization

that works in unison to strategize and implement sustainable energy policy with an emphasis on

inclusion (Mohammed 2013).

America’s  Great  Outdoors  Agency  Collaboration America’s  Great  Outdoors  (AGO)  is  an  initiative launched in 2010 that is aimed at restoring

American commitment to conservation. One of the focal points of initiative is that it is a non-

partisan effort that is largely supported by public opinion. The United States Government has a

strong coalition of agencies involved in the effort to revitalize conservation in America; major

agencies involved include the Council for Environmental Quality, the Office of Management and

Budget, the Environmental Protection Agency, the Department of the Interior, and many other

similar agencies. On top of a more collaborative inter-governmental process, public opinion

strongly backs the initiative and comprehensively incorporates a 10,000 person survey with over

50 public listening sessions. The overwhelming majority suggests a move toward protecting the

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environment  and  the  America’s  Great  Outdoors  delineates  the  key  steps  necessary  for  a  national  

renewal focused on conservation. Most important, this cross agency collaboration through AGO

is aimed at driving effectiveness in policy making and implementation. The task of the

government  coordination  is  to  “coordinate  intergovernmental  efforts,  report  to  president  on  

goals, one-stop access location, and communicate with local communities”  (USA  2011).

Recommendation for Restructuring Collaboration in Chile There is a strong precedent for inter-ministerial groups in the Chilean Government. Specifically

in renewable energy, in 2009 Chile created the CER, the Center for Renewable Energy. This

committee is overseen by ministers from in Education, Agriculture, Economy, National Assets,

Entrepreneurship,  Energy,  and  Environment  to  address  concerns  over  renewable  energy’s  

standing in Chile (CER 2013). The  group’s  mission  is  to  “ensure optimal participation of NCRE

in Chile's Energy Matrix, in order to contribute to sustainable development”  (CER  2013). The

CER is primarily focused on promotion of project, providing information, building capacity and

promoting participation. The transition of the CER from a medium and smaller scale energy

organization to a large national scale policy maker would help guide Chile down a path of

sustainable development with renewable energy at the core. In order to drive this transition, the

CER needs to restructure and refocus its approach by focusing on these key areas: redirecting

attention to national policy, increased political participation, and fostering direct involvement

with the Chilean public. By focusing on three sub initiatives, there is immense opportunity for

improvement in Chile regarding agency collaboration

The agency in focus, the CER, has yet to directly tackle policy and rather has targeted

small and medium scale projects. The goal is that this framework of participation with

smaller stakeholders in the CER can be scaled to incorporating the CER as a larger policy

making group within the Chilean Government. The CER should issue a national policy

agenda for attacking the renewable energy needs and promoting sustainable development.

Having only seven of twenty-two ministries on the board, the CER is not yet optimally

suited to transition to a national policy making group. In order to truly take a multi-

stakeholder approach and provide political power, all or most ministries should be part of

the discussion on reforming renewable energy and conservation. Ignoring the impact on

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one ministry may lead to an unsustainable long term policy. The CER should expand its

reach within the political realm of Chile to incorporate additional policy leaders.

Even  more  important  to  the  CER’s  agenda,  there  is  a  need  to  address  the  public  voice  in  

construction of this policy. Similar to the structure of the AGO, the new policy initiative

should reach out to the public first for acceptance and direction in renewable energy and

conservation. This will drive a sustainable approach to consider all relevant arenas of

implementing a renewable energy policy with a focus on conservation. Chile should

sponsor the CER to begin a national campaign regarding the public importance of

conservation and renewable energy.

America’s  Great  Outdoors  Partnerships AGO is also focusing on implementation and execution partners for this national scale

transformation. The same will need to be true of Chile. There is a need to incorporate all actors

and additional groups with similar viewpoints to emphasize efficient execution. For the AGO,

they  are  “using partnerships with private and public sector to help realize conservation.

Collaboration will be encouraged between the public and private sectors; state, local, and tribal

governments and the private sector; between natural resource and cultural resource interests; and

between local communities and the federal government” (USA 2011). By focusing on multi-

stakeholder approach tied to process efficiency, partnerships will help advance Chile by focusing

on opportunities in sustainability and implementation. Sub-initiatives to integrate all these

stakeholders are developing close partnerships and creating a CER sponsored convention.

Recommendation for Increasing Partnerships in Chile There is a great possibility for integrating a wide variety of organizations to move forward

conservation focused renewable energy policy.

By working with organizations that are directly involved on the ground and have large

influence, policy makers can gain incredible insight into the direct and indirect impacts of

its policy. The CER can push for partnerships, large conventions to share ideas, and

linked incentives. Specifically, the CER can partner with corporations, like Enel Green

Power, or large development partners, like the World Bank. Partnerships with these

organizations could reduce waste and create access to financing.

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Currently,  the  Chilean  International  Renewable  Energy  Congress  (“CIREC”)  gathers  

important stakeholders in the renewable energy sector in Chile. Another recommendation

to promote large scale transformation is to incorporate a wider variety of stakeholders

and partners in a CER sponsored large annual convention, similar to the CIREC, on the

importance of renewable energy and conservation in Chile. Especially important in

creation of a conference is to include the public and non-profit sector into the

conversation; currently CIREC includes neither. Coinciding with restructuring the CER,

A sponsored convention could help to progress the CER as a national policy maker.

Key Recommendations The government of Chile should:

Refocus the CER to include large-scale policy initiatives in Chile

Expand the CER to include all ministries of Chilean Government

Address the public opinion through a national campaign

Develop strong partnerships across sectors

Sponsor an annual convention focused on conservation and renewable energy

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Sustain Impact with Measurement and Enforcement

There are two separate levels of looking at how to measure the effectiveness of the proposed

policy: the efficiency of the permitting process and the achievement of overall goals. For the

efficiency of the permitting process, items to consider are the time and cost to permit and

consistency between design and construction. To determine whether this policy is effective in

achieving the overall goal of meeting energy demands while mitigating adverse effects on the

environment, analysis should focus on the measurement of indicators of green growth and

continued monitoring and data collection. Ultimately, a measurement of policy effectiveness

must also consider the enforcement of the policy and consequences of not meeting certain

standards. This measurement system will hold all parties accountable; the government will be

held accountable to ensuring the policy is effectively promoting conservation and incentivizing

renewable energy development, and companies will be held accountable to compliance with any

mitigation or compensatory mitigation strategies agreed upon in the project approval. This

strategy to measure impact and effectiveness will additionally be used to construct future policy

adaptations.

Policy Efficiency The efficiency of the permitting policy can be determined by looking at quantitative statistics.

First, the time required for each project to receive a permit from the initial application to the start

of operation should be documented. The results should be aggregated to ensure that the time is

within the maximum time set as the goal for this policy. If the time to permit exceeds this

maximum for a significant number of projects, there must be investigation into the causes.

However, there must always be a balance between faster permitting and thorough environmental

assessment. Second, the cost of permitting must be documented to ensure that companies are

incentivized to develop renewable energy projects on land set aside specifically by the

government, and that cost to permit is not a deterrent. In addition, efficiency of permitting policy

depends on consistency between the initial proposal, design, and final construction. If the project

is approved based on the environmental assessment that is conducted with the information given

in the initial design, then it is imperative that these plans are followed. The inspection of the

project at the beginning of operation should clearly detail whether the environmental footprint

agrees with the initially projected ideas. If it does not coincide, the company must submit a

35

report of the reasons for any significant changes made in the design and how these changes

reduce further harm to the environment.

Policy Effectiveness Ensuring that the policy is efficient does not necessarily mean that the policy is working towards

the overarching goals of energy production and conservation of natural habitat. To develop a

system of criteria that indicate progress towards policy goals, The Organization for Economic

Cooperation  and  Development’s  (OECD)  strategy  for  green  growth was used as a model. The

OECD is developing a method of measuring green growth using indicators of the main themes of

green growth: the natural asset base, the environmental productivity of the economy, the

environmental dimension of quality of life, and the socio-economic context (UNEP 2013). These

indicators can also serve as the foundation for a measurement strategy for Chilean renewable

energy policy.

1. Natural Asset Base Analyzing the natural asset base will characterize the natural resources of an area to determine

threats from depletion and degradation which allows for the minimization of risk by

development. Analysis also focuses on whether the depletion of this resource harms growth,

which depends on whether the depletion can be compensated for in another asset (UNEP 2013).

In the proposed policy, characterization of threats to a natural asset base and possibilities for

compensatory mitigation should be completed during siting procedures. However, while this

information provides a baseline, continued monitoring of the natural assets must be conducted

throughout the lifespan of the project to ensure long-term compliance with the initial standards

set. If a compensatory mitigation strategy was deemed necessary, analysis of the natural asset

base will determine whether these compensatory efforts are actually having the desired effect on

the ecosystem.

2. Environmental and Resource Productivity Secondly, data must be collected to research environmental and resource productivity, which

“measures  whether  growth  or  output  and  consumption  are  achieved  with  fewer  natural  resource  

inputs including less pollution and a lower reliance on environmental service”  (UNEP  2013).  

This indicator will be used to measure the energy outputs of each renewable energy project in

Chile compared to the strain on environmental resources or biodiversity associated with the

project. This could then be used to find exceptional projects to inform future siting or

36

recommendations. In addition, a comparison with plants in operation before the implementation

of this policy would show whether the policy is effectively increasing renewable energy output

while minimizing negative environmental effects.

3. Environmental Quality of Life Next, studies must be conducted to research the environmental quality of life which looks more

in-depth in other categories, such as air and water pollution. Environmental quality assessments

are crucial in determining whether there are any adverse effects caused by operation of the

project, especially in terms of negative effects on human health.

4. Socio-economic Context Finally, the socio-economic context of the project must be characterized in order to measure the

impact of social inclusion programs that are incorporated into the policy. Measurement should

focus on exploring how public opinion about renewable energy projects has changed as a result

of awareness campaigns and the inclusion of all stakeholders in decisions. This analysis will also

focus on the creation of jobs in conservation and operation and maintenance of plants to

determine the effects on the local economy.

Monitoring Analysis of these four indicators requires sustained monitoring of each project. Baseline data will

be collected during the initial siting to inform and develop environmental assessments of each

site. However, data collection must also be sustained throughout the duration of the project to

ensure that there are not new or unanticipated environmental threats. This system of data

collection must also be consistent so that data can be compared between different sites.

The Bureau of Land Management is currently working on a monitoring strategy for their

renewable  energy  projects  that  is  based  on  their  current  “Assessment,  Inventory, and Monitoring

Strategy”  for  general  BLM  land.  Their  strategy  outlines  processes  including  the  development  of  

consistent ecosystem indicators, using a statistically valid sampling framework, integrating

remote sensing technology, and incorporating this data into comprehensive land management

plans (BLM 2011b). This strategy allows the BLM to assess the resources of the ecosystem,

determine the location and pattern of any disturbances, understand how these components should

affect policy for the area, and ultimately to determine if mitigation actions are contributing

towards the objectives laid out in the initial permit (BLM 2011b). This strategy could help

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inform the data collection for characterization of the natural asset base. However, each indicator

will require a different method for monitoring, ranging from quantitative data collection to

surveys of the public.

Enforcement For this policy to be successful there must also be clarity in the expectations of compliance and

the consequences for non-compliance. Continual monitoring will facilitate enforcement as the

characterization of the natural asset base and environmental resources will examine whether the

project has adhered to the proposed mitigation and compensatory mitigation strategies. Because

monitoring will be occurring regularly throughout the duration of the project, comprehensive

inspections should also happen more frequently. Currently, the Bureau of Land Management

reviews their Right of Way grants for the first time at the end of ten years and then at regular

intervals to determine if any changes need to be made to the grant. However, more frequent

inspections would ensure greater compliance with mitigation strategies and also provide

verification that the mitigation strategies are effective. If any inspections show non-compliance

with policy standards, then there must be consequences that were stipulated in the original

contract.

Key Recommendations The government of Chile should:

Develop a strategy for measuring the impact of the policy after implementation

Measure the time and cost to receive a permit to determine policy efficiency

Monitor the natural asset base, environmental productivity, environmental quality of

life, and socio-economic context to determine policy effectiveness

Conduct long-term monitoring and frequent inspections

Ensure there is established protocol for cases of non-compliance

38

Conclusion

Chile is currently engaged in an unprecedented, collaborative effort to dramatically shift its

energy reliance to non-conventional renewable energy sources. In this process, Chile has the

opportunity to become a global leader in environmentally conscious project development and

implementation. To achieve this goal, Chilean policy must place its focus on conserving natural

resources and protecting the rights of local populations. This analysis has provided five policy

recommendations that guide NCRE projects through conception, planning, implementation, and

finally, long-term assessment and support. By driving conservation focus into policy, improving

permitting efficiency, emphasizing social inclusion, increasing agency collaboration, and

sustaining impact through measurement and enforcement, Chile can achieve rapid yet

responsible NCRE development that offers long-term protection for both the Chilean people and

the  country’s  invaluable  natural resources. These recommendations provide the framework for

future dialogue within the Chilean Government in order to implement these suggestions into

effective policy. In doing so, Chile can achieve energy independence while providing a global

model for other countries to follow.

39

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