嘉義布袋鹽田 / 林坤慧 攝
Budai Wetland, Chiayi County / Kun-hui Lin
嘉義布袋鹽田 / 呂翊維 攝
Budai Wetland, Chiayi County / Allen Lyu
台南將軍鹽田 / 林坤慧 攝
Jiangjun Salt Pans, Tainan City / Kun-hui Lin
台南將軍鹽田 / 李昱緯 攝
Jiangjun Salt Pans, Tainan City / Yu-wei Li
Nationalized Salt Pans are Not Degraded Habitats; The Conservation Movement Should Not Be Moving Backwards
In May 2021, an online media platform published a piece by an academic who noted that habitat degradation at salt pans in Chiayi County and Tainan City was worsening and that it needed to addressed. The piece also criticized prior analysis of salt pans for ecologically sensitive areas as not being rigorous enough. The study, done by the Council of Agriculture's Taiwan Endemic Species Research Institute (TESRI), led the National Property Administration (NPA) to put forward an administrative order blocking photovoltaic development in certain areas. The article closed with the academic calling on the NPA to withdraw its current administrative order and allow photovoltaic manufacturers to apply for projects in these areas. The companies would then be able to devote resources towards rehabilitation and management of these salt pans, creating a win-win situation for both green energy and conservation.
The Taiwan Wild Bird Federation, the Wild Bird Society of Tainan, the Taiwan Black-faced Spoonbill Conservation Association, and the Kaohsiung Wild Bird Society all share a different opinion to that of this submission. Our statement on the matter is as follows:
Most Nationalized Salt Pans are Avian Ecological Hotspots, not Degraded Habitats
The nationalized salt pans along the coast of Chiayi County and Tainan City are important habitats with the largest and most concentrated numbers of migratory waterbirds in the country. Over the last few years, surveys conducted by TESRI and National Cheng Kung University, as well as data provided from both birdwatchers and citizen science projects, have all confirmed that these salt pans are undoubtedly waterbird hotspots. They are particularly important for wintering waterbirds such as ducks, geese, sandpipers, plovers, egrets, herons and gulls. In fact, around 35,000-40,000 birds are counted at Chaiyi's Budai Wetland each winter, making it one of the most important salt pans in the country. This is the highest concentration and number of waterbirds in the country. Meanwhile, Tainan City's Jiangjun and Dingshan salt pans see anywhere from 1,000-10,000 waterbirds each year, including globally threatened species such as the Spoonbilled Sandpiper and Nordmann's Greenshank. Whether looking at these numbers from either a regional or national scale, be it species or individuals, these salt pans are critically important. We believe that the ecological conditions of such bird-rich areas are still quite good, not degraded, which is the main reason why these areas are not suitable for photovoltaic energy projects.
Habitat Degradation Should be Actively Managed, Installing Photovoltaics is not the Solution
Of course if the environmental conditions at the salt pans are really deteriorating, it should be actively addressed. After Taiwan's salt industry halted production, the salt pans were left idle and unmanaged. Rainfall amounts and water level control at sluice gates became major factors affecting the ecology of these sites. However, we cannot agree with this notion of portraying well-known ecological hotspots as degraded habitats and rationalizing the impact of photovoltaic development with "low disturbance"; thus allowing manufacturers to develop and then rehabilitate these area. We must emphasize that the installation of large photovoltaic panels on salt pans is definitely not "low disturbance" to the waterbirds that need large open areas for both feeding and roosting. To protect the local ecology for birds, priority should be given to preserving the existing and already ecologically-sound salt pans. This is better than allowing photovoltaics companies to develop these areas and then provide some form of ecological compensation later. This is like putting the cart before the horse. There is also no guarantee that spending large amounts of money on habitat restoration will restore these areas to their original ecological appearance or function.
Salt Pan Photovoltaic Projects Disturb Local Ecology, Avoiding Ecological Hotspots is the Way to Go
Since 2017, the Ministry of Economic Affairs (MOEA) has been promoting photovoltaic demonstration sites in both Chiayi and Tainan's salt pans. After excluding existing conservation areas protected by law, a total of 758 ha of salt pan were designated for photovoltaic installations. Yet these were still located in the richest and most important waterbird habitats in Taiwan. The abundance of birds in these areas is no less than that of the neighboring legally protected areas. This led to controversy surrounding the impact of photovoltaic developments on local ecology. Therefore, several rounds of talks and consultations took place between the Executive Yuan, the MOEA, the Council of Agriculture, and local civic groups, resulting in TESRI preparing an ecological sensitivity map for the nationalized salt pans (including data from TESRI, National Cheng Kung University, and the eBird record database). After consulting the created sensitivity maps, areas of high ecological sensitivity were to be excluded from photovoltaic demonstration project sites. Meanwhile, areas of low and medium ecological sensitivity were to be used instead. The Section 8 Photovoltaic Installation in Yizhu, Chiayi (80 ha), the Section 9 Photovoltaic Installation at Xinying, Chiayi (22 ha), and the Salt Pan Photovoltaic Installation in Tainan (213 ha) have all been completed already.
In fact, regardless of the level of ecological sensitivity at these salt pans, they could all have some form of ecological function and value if effectively managed. However, avoiding areas of high ecological sensitivity is part of a trade-off between green energy policy and ecological conservation. The photovoltaic installation plans for both Section 8 and Section 9 in Chiayi include portions dedicated to habitat restoration and habitat compensation. Yet the goal there is to minimize the impact of development, not avoid impact altogether. In lieu of the rapid global loss of natural wetlands, and to protect this permanent habitat of migratory birds, we believe that in the future, important bird habitats should be preserved, and that new photovoltaic installments should not be placed on these nationalized salt pans. However, last year (2020), the consensus between the Executive Yuan and civic groups was not conveyed to the NPA, so there were still some photovoltaic companies continuing to apply to the NPA to develop highly sensitive ecological areas. After our organization issued a statement alongside numerous conservation-related organizations and scholars, the NPA called a meeting to understand the seriousness of the problem. It was then decided that all applications for photovoltaic installments in highly sensitive ecological areas would be stopped or withdrawn, thus eliminating the pressure of large-scale development in these environments.
To Reduce the Conflict Between Photovoltaics, Ecology, and Society, the Key is Consensus, Not Going Backwards
Recently, the country's photovoltaics policy has experienced various controversies. In order to reduce conflicts between the environment and society and with the goal of still reaching the nation's 2025 green energy goals, the MOEA has increased proportion of rooftop photovoltaics and reduced the proportion of ground photovoltaics. In addition, the MOEA, in cooperation with the Council of Agriculture, have given priority to the implementation of "floatovoltaics", a fishery and electricity symbiosis-type installment that adds value to the fish farm's economic prospects. An environmental and societalal review mechanism (ESR), which aims to inventory various potential conflicts for photovoltaic manufacturers in order to devise effective countermeasures to reduce such issues, has also been created. At present, the development of floatovoltaics is still in its preliminary implementation stage and the results are yet to be determined. Meanwhile, the ESR has not been applied to other forms of ground-type photovoltaic projects (such as on agricultural land or traditional fishponds). Recently, some scholars now question the credibility of TESRI's assessment of salt pan ecological sensitivity while also advocating for the photovoltaic industry to be able to develop and rehabilitate degraded salt pan habitat. Comments such as these look to revive an issue which has already been settled and may once again stigmatize the country's green energy policy as one that is damaging to the environment. We can expect that the controversy surrounding photovoltaic power will not disappear anytime soon, but it should be the consensus of most people in Taiwanese society to reduce the conflict between photovoltaic power and ecology and society. We should not go backwards.
Civic Groups Plan to form an Alliance to Adopt Nationalized Salt Pans, Creating a New Way Forward
Although nationalized salt pans in Chiayi County and Tainan City are currently rich in bird ecology, in the absence of actual management, there are inevitably going to be issues related to illegal encroachment, fragmentation, dumping of waste, etc. To promote the sustainable management of nationalized land, the NPA has been encouraging local environmental groups to adopt "National Non-Public Use Marginal Land". In February of this year it announced the principles of the revised regulations for lands under this classification, including coastal areas, wetlands, traditional fishponds, mountain areas and other public lands. Currently, the Taiwan Black-faced Spoonbill Conservation Association has adopted salt pans in Tainan City's Dingshan Area while the Kaohsiung Wild Bird Society has adopted salt pans in Section 10 of Chaiyi's Budai Wetland. These groups are entrusted to maintain the local environment and monitor the movement of birds through regular patrol work and water level control. To further watch over these precious salt pans into the future, civic groups in Tainan, Kaohsiung and Taipei are in talks to form an alliance and are expected to jointly apply to the NPA to adopt more nationalized salt pans in Chiayi County and Tainan City. These NGOs hope that by working together, these important salt pans can be preserved and ecological coexistence through long-term monitoring and patrol, community cooperation and education, and effective habitat management can be maintained.