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Emerging Standards and Challenges in Pakistan's Renewable Energy Decommissioning and Mining

Sahar Iqbal

Summary

  • As Pakistan increasingly shifts toward renewable energy to meet its growing energy demands and to mitigate environmental degradation, the issue of decommissioning renewable energy projects and the ethical sourcing of materials becomes paramount.
  • This article delves into the emerging industry standards for renewable energy decommissioning, the potential higher standards for the renewables sector compared to the petrochemical industry, and the ethical considerations surrounding the mining of rare earth metals necessary for renewable energy development.
Emerging Standards and Challenges in Pakistan's Renewable Energy Decommissioning and Mining
Muhammad Aqib via Getty Images

Decommissioning and Mining in Pakistan's Renewable Energy Industry: Emerging Standards and Challenges

Decommissioning and site preparation is often a complex and lengthy process, as it includes hazardous material removal, soil and groundwater remediation, and structural demolition and disposal of infrastructure and products built to further renewable energy transmission and use. Decommissioning is the last stage in the life cycle of exploration and production. Pakistan Nuclear Regulatory Authority (PNRA) S.R.O. 798(I)/2012 defines decommissioning of such infrastructure and products in section 2 (f) as “administrative and technical actions taken to allow the removal of some or all of the regulatory controls from an installation (except for a repository or for certain nuclear installation(s) used for the disposal of residues from mining and processing of radioactive materials, which are closed and not decommissioned).” Abandonment or decommissioning activities are carried out at the end of the Development and Production Lease (D&P Lease) period or if the oil and gas reserves have been extracted to the extent that it is no more commercially feasible to extract the reserves, or the reserves have expired before the end of D&P Lease period

As Pakistan increasingly shifts toward renewable energy to meet its growing energy demands and to mitigate environmental degradation, the issue of decommissioning renewable energy projects and the ethical sourcing of materials becomes paramount. With billions of dollars being funneled into renewable energy generation and storage projects, it is essential for policymakers and industry players to focus on sustainable and responsible practices. This article delves into the emerging industry standards for renewable energy decommissioning, the potential higher standards for the renewables sector compared to the petrochemical industry, and the ethical considerations surrounding the mining of rare earth metals necessary for renewable energy development.

Industry Standard Renewable Energy Decommissioning Standards

Decommissioning renewable energy projects involves dismantling and disposing of wind turbines, solar panels, and battery storage systems in an environmentally responsible manner. As Pakistan ramps up its investment in renewable energy, establishing decommissioning standards becomes critical to avoid environmental degradation. Section 8 (2) of PNRA S.R.O. 798(I)/2012 stipulates proper licensing from the Authority for Decommissioning of a nuclear installation or closure of waste repository. The licensee must apply for decommissioning at least three years before terminating the operation of a nuclear installation. At the end of decommissioning activities, the licensee should apply for removal of regulatory control and submit a decommissioning completion report. These various stipulations are to match the global standards and to ensure safety of the site and nearby habitats. In addition to PNRA, Pakistan Atomic Energy Commission (PAEC) is another organization that is responsible for decommissioning of nuclear power plants in Pakistan. PAEC initiated nuclear full cycle activities in the early 1960s and have designed high standard waste management systems for Karachi Nuclear Power Plant (KANUPP) and Chashma Nuclear Power Complex (CHASNUPP).

Globally, the renewable energy sector is expected to adhere to stringent decommissioning standards, often surpassing those applied to the petrochemical industry. This is due to the nature of renewable projects, which are often financed and supported by environmentally and socially conscious investors. For instance, wind turbine blades, primarily composed of composite materials, present recycling challenges. To address this, countries like Germany have implemented regulations requiring the recycling of up to 85 percent of wind turbine components. Pakistan can take inspiration from such standards and establish its own regulations to ensure sustainable decommissioning practices.

Higher Standards for the Renewables Industry

The renewable energy sector in Pakistan is likely to be held to higher standards compared to the petrochemical industry. This stems from the global emphasis on sustainability and the ethical imperatives tied to green investments. The adoption of higher standards is driven by the need to minimize the environmental footprint and to adhere to the principles of environmental, social, and corporate governance (ESG). Pakistan is a signatory to the Kyoto Protocol and the Paris Agreement, which allow access to global carbon crediting markets and environment and climate funds.

All provinces of Pakistan participate in the establishment of renewable energy policy and incentives at the federal level through the Council of Common Interest, which is composed of representatives from each province. Every province has a department that works on developing energy policies. The Pakhtunkhwa Energy Development Organisation, the Sindh government's Energy Department, the Punjab Power Development Board, and the Balochistan government's Energy Department are some of these provincial departments. Similar departments exist in Gilgit Baltistan (Water and Power Department) and AJK (AJ&K Electricity Department, AJK Power Development Organisation). For each province, the provincial governments may create incentives.

In Pakistan, the National Electric Power Regulatory Authority (NEPRA) has begun to integrate sustainability criteria into its regulatory framework. Projects that do not comply with stringent environmental standards may face difficulties in obtaining necessary approvals and financing. This regulatory shift ensures that renewable energy projects contribute positively to environmental conservation. The NEPRA Social Investment Guidelines 2021 S.R.O. 1459(I)/2021 is an initiative to protect the environment and to mitigate adverse climate change, promote wellbeing of local communities and human development in the electric power sector to ensure that power brings prosperity. The press release of these guidelines  executive officer of mining companies as well as representatives of PAEC along with other leading power sectors and authorities.

Recycling Commitments and Regulatory Approvals

For renewable energy projects to gain regulatory approval and investor support, a significant portion of the project’s facilities must be pledged to recycling. In Pakistan, the Alternate Energy Development Board (AEDB) plays a pivotal role in mandating recycling commitments as part of the project approval process. Moreover, Pakistan has a National Hazardous Waste Management Policy 2022 established by the Ministry of Climate Change, which is an instrumental initiative under the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal. By incorporating recycling targets into the initial project proposals, developers can demonstrate their commitment to sustainability.

Ethical Sourcing of Materials

One of the most pressing concerns in renewable energy development is the ethical sourcing of rare earth metals, essential for the construction of solar panels, wind turbines, and battery storage systems. Rare earth mineral mining, particularly open-pit mining, poses significant environmental and social risks, including water and energy consumption, land degradation, and community displacement.

In Pakistan, the Thar coal mining project provides a cautionary tale. Despite being a coal mining project, it illustrates the broader issues associated with large-scale mining operations, such as land acquisition and environmental degradation. Renewable energy projects must avoid repeating these mistakes by adopting stringent sourcing standards.

Investor Requirements and Mitigating Externalities

Environmentally and socially conscious investors are increasingly demanding that renewable energy projects mitigate the externalities associated with rare earth mineral mining. These investors may require developers to adopt best practices in mining, such as minimizing water and energy use and ensuring proper land reclamation post-mining.

The Government of Pakistan can take proactive steps by incorporating these requirements into national policies. The establishment of the Mineral Development Framework by the Ministry of Energy (Petroleum Division) is a step in the right direction. This framework can include guidelines for the ethical sourcing of materials and mandates for companies to comply with international environmental standards.

As Pakistan continues its transition toward renewable energy, the establishment of robust decommissioning standards and the ethical sourcing of materials are crucial. By learning from international best practices and integrating stringent regulations, Pakistan can ensure that its renewable energy projects are not only environmentally sustainable but also socially responsible. The implementation of comprehensive policies by regulatory bodies such as NEPRA and AEDB will play a vital role in shaping a sustainable energy future for Pakistan. Through a multifaceted approach that includes technological innovation, regulatory oversight, and public awareness, Pakistan can navigate the challenges of renewable energy decommissioning and mining, setting a benchmark for other developing nations.

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