Guidelines in Securing Environmental Compliance Certificate (ECC) under the Philippine Environmental Impact Statement System (PEISS) for Floating Photovoltaic (FPV) Projects on Inland Freshwater Bodies

DENR Administrative Order No. 2025-20

Subject: Guidelines in Securing ECC under the Philippine EIS System for Floating Photovoltaic (FPV) Projects on Inland Freshwater Bodies

Signed: May 18, 2025 . Published: June 2025 . Acknowledged: ONAR, U.P. Law Center, June 11, 2025 . Note: amended by DAO 2025-30.

Rationale and Policy

Supports the Philippine Energy Transition Program by enabling FPV development without competing for land, while protecting freshwater bodies. Given scientific uncertainty and limited baseline data, the Precautionary Principle applies to EIA evaluation, and the mitigation hierarchy (avoid, minimize, restore, compensate) governs mitigation.

Scope

All FPV projects on inland freshwater bodies (water with less than 500 ppm dissolved salt, per DAO 2016-08), including projects that already hold an ECC or a DOE Renewable Energy Service Contract.

Categorization and Documentary Requirements

FPV projects are Category B (non-ECP in an Environmentally Critical Area) under EMB MC 2014-005 and must secure an ECC.

• Above 100 MW or a footprint above 100 hectares: EIS Report, with the DOE RE Service Contract, the feasibility study submitted to DOE, a Project Description for Scoping, and IEC documentation (focus group discussions per DAO 2017-15, proof of IEC materials received by LGUs, and Initial Perception Survey results).
• Below 100 MW or a footprint below 100 hectares: IEE Checklist Report (Annex B form), with the DOE RE Service Contract, feasibility study, and project description.
• Existing, expanded, or modified projects: categorized under EMB MC 2014-005 Annex B, or an amended IEE Checklist, with the prior ECC. Operating projects without an ECC use an EPRMP.
• Annex A sets coverage thresholds for associated components, including onshore transmission lines, underwater power cables, and substations.

Jurisdiction and Review

EMB Regional Offices evaluate all FPV EIA reports. For projects spanning regions, the region with the largest coverage leads an inter-regional committee. DOE Renewable Energy Management Bureau experts sit as resource persons on the EIA Review Committee. EMB Regional Offices submit quarterly compliance evaluation reports to DENR.

Enhanced EIA Process

• Before IEC, a high-level environmental and social assessment of the host waterbody covering carrying capacity, cumulative impacts of multiple projects, climate risk, and site suitability.
• A proponent-led Initial Perception Survey, socio-economic surveys, and stakeholder mapping (Annex E stakeholder directory, including 40% women's representation) before public scoping, plus a grievance redress mechanism.
• The EIA covers all components: floats, panels, inverters, buried cables, onshore substations, and transmission lines.
• Process follows the Revised Procedural Manual of DAO 2003-30 (Annex F flowchart), with DAO 2017-15 and EMB MC 2020-30 applying suppletorily.

Environmental and Social Considerations by Phase

• Pre-construction: site suitability (access, irradiation, typhoon and flood exposure, waterbody size and depth); avoidance of critical habitats, protected areas, KBAs, Ramsar sites, livelihood and cultural areas; and no siting in watersheds and protected areas designated as ECAs, including Class AA public water supply. Seasonal (wet and dry) baselines for water quality across littoral, limnetic, and benthic zones (including COD, algal concentration, and chlorophyll-a), air, noise, GHG (Scope 1 and 2, preferably Scope 3), climate and disaster risk, aquatic and terrestrial biodiversity (with Critical Habitat Assessment where needed), contaminated land, livelihoods, cultural heritage, navigation, and land and water use conflicts.
• Construction: ECC compliance with SMRs and CMRs; sediment, spill, underwater noise, and invasive species controls; scheduling around breeding and spawning; community health, navigation safety, and livelihood support.
• Operation and maintenance: monitoring of stratification, dissolved oxygen, shading, leaching, and glare; non-toxic materials; biodiversity no net loss or net gain where critical habitats are affected; waste management; ongoing engagement and local hiring.
• Decommissioning: an Abandonment and Termination Plan submitted to EMB at least one year before decommissioning, removal of subsurface infrastructure, recycling, re-baselining, and site restoration.

Additional Requirements (Annex G)

Proof of authority over the site (water rights, lease, DOE service contract), PAMB clearance within protected areas, foreshore lease application for floating facilities, and Letters of No Objection from DA, DILG, DND, DOT, and DICT within one year of ECC issuance.

Effectivity

Takes effect fifteen (15) days after publication in a newspaper of general circulation and upon acknowledgement by ONAR.

Signed by Secretary Maria Antonia Yulo Loyzaga. Summary prepared by EnviSynergy from the official DENR issuance; refer to the full text for binding provisions.