DENR issues the Guidelines in Securing an Environmental Compliance Certificate (ECC) under the Philippine Environmental Impact Statement System (PEISS) for Floating Photovoltaic (FPV) Projects on inland freshwater bodies

The Department of Environment and Natural Resources (“DENR”) issued DENR Administrative Order No. 2025-20 (“DAO 2025-20”) which aims to ensure that Floating Photovoltaic (“FPV”) development on inland freshwater bodies within the country adheres to the highest environmental sustainability standards. The issuance highlighted that the newly released guidelines are applicable to all FPV projects on inland freshwater bodies within the country, including those previously issued an Environmental Compliance Certificate (“ECC”) by the Environmental Management Bureau (“EMB”) or a Renewable Energy (“RE”) Service Contract by the Department of Energy (“DOE”).

DAO 2025-20 clarifies that FPV projects are categorized as a Category B Project or projects which are not classified as Environmentally Critical Project (“ECP”) but which are deemed to significantly affect the quality of the environment. Generally, FPV projects are required to secure an ECC.

As to the jurisdiction on FPV Projects, it generally lies with the DENR-EMB Regional Office where the project is located. However, when there are complex cases where jurisdiction is unclear, the EMB Director may assign the nearest office as the lead and if disputes arise over jurisdiction among DENR-EMB Regional Offices, the matter is escalated to the EMB Director for resolution. For projects crossing LGUs, provinces, or regions, inter-regional committees are to be established as needed and the lead office will be from the region with the largest coverage of the project area.

Documentary Requirements for ECC Applications 

Under the Guidelines, the requirements differ depending on the capacity of the FPV project or on the operations of the said project. 

For projects with a capacity of at least 100 MW or a footprint of 100 hectares or more, new applicants must submit an Environmental Impact Statement (EIS) Report, a DOE RE Service Contract, feasibility study, Project Description for Scoping (PDS), IEC documentation, and an initial perception survey. Existing projects undergoing expansion, modification, or rehabilitation must additionally submit their prior ECC.

For projects below 100 MW or with a footprint smaller than 100 hectares, new applicants are required to submit an Initial Environmental Examination (IEE) Checklist Report, along with the DOE Service Contract, feasibility study, and Project Description. Existing projects must submit an amended IEE Checklist, updated project description, prior ECC, and their RE Service Contract.

General Environmental and social Considerations Across FPV Project Phases

During the pre-construction phase, Philippine Environmental Impact Statement System (“PEISS”) activities which shall be conducted include an information and education campaign (“IEC”), public scoping, technical scoping, and Environmental Impact Assessment (“EIA”) reports. For the environmental considerations during this phase, several assessments must adhere to relevant government issuances released by agencies. Such assessments include the water quality assessment and monitoring, air quality impact assessment, greenhouse gas assessment, noise impact assessment, assessment of meteorological and climatological factors, climate and disaster risk assessment, critical habitats assessment, terrestrial biodiversity assessments, and a comprehensive contaminated land assessment.

In the construction phase, there is a need to strictly adhere to the conditions outlined in the ECC while complying with the required monitoring activities and timely submission of Self-Monitoring Reports (“SMRs”) and Compliance Monitoring Reports (“CMRs”) to EMB. Among those that the FPV project must comply with during this phase includes, but not limited to, the water quality monitoring, maintenance of effective grievance redress mechanisms (“GRM”), regular air quality monitoring, noise reduction methods, ecological watching brief, and mitigation measures and management plans developed as part of the EIA process in the pre-construction phase.

As FPV projects transition to the operation and maintenance phase, the focus shifts to the ongoing functionality and efficiency of the FPV facilities. Site presence is significantly reduced, limited primarily to scheduled inspections and maintenance tasks. They must still submit reports including SMRs and CMRs. Aside from these, there is a need for ecological monitoring, community-based biodiversity and ecosystem services monitoring.

Once the project starts to shift to the decommissioning phase for the systematic removal of the FPV project equipment and structures, a comprehensive Abandonment and Termination Plan (“ATP”) must be submitted to the EMB at least one (1) year prior to the FPV project’s decommissioning. Restoration of the site to its original condition to the extent feasible, along with the effective management of any waste and debris generated during decommissioning, forms an integral part of this phase.

The full text is available in this link.