Ultra vires approval! Filing of Hainan 100MW fishing-photovoltaic complementary + energy storage project is invalid

2026-10-10 13:09:16

Wenchang Business Environment Construction Bureau said that the project is a centralized photovoltaic project, and the Bureau has no right to accept and file. The window staff of the Bureau did not strictly check the authority of centralized photovoltaic power generation project filing, and exceeded their authority to examine and approve the project filing for the Department, which was beyond the statutory authority.

On October 10, the website of Wenchang Municipal People's Government of Hainan Province issued a notice from Wenchang Business Environment Construction Bureau on the invalidation of the filing of "Shengshi Wenchang Overseas Chinese Farm 100m W Fishing-Light Complementary + Energy Storage Photovoltaic Power Generation Project" . The

notice shows that on September 12, 2025, Hainan Shengshi Clean Energy Co., Ltd., the construction unit of the project, declared the "Shengshi Wenchang Overseas Chinese Farm 100MW Fishing-Light Complementary + Energy Storage Photovoltaic Power Generation Project" for the record through the online approval and supervision platform of investment projects in Hainan Province. (Project code: 2508-469005-04-01-454792).

However, Wenchang Business Environment Construction Bureau issued a notice on October 10, 2026 that the project is a centralized photovoltaic project, and the Bureau has no right to accept and file it. The window staff of the Bureau did not strictly check the filing authority of the centralized photovoltaic power generation project, and exceeded their authority to examine and approve the project filing for the company, which was beyond the statutory authority .

越权审批!海南100MW渔光互补+储能项目备案失效1

The Bureau said that according to the relevant regulations, the installed capacity of the project is 100MW, covering an area of about 2000 mu, using fishing ponds, including water surface construction, is a centralized photovoltaic project of fishing-photovoltaic complementary mode, which is not applicable to distributed photovoltaic filing regulations . Centralized photovoltaic projects must go directly to the Hainan Development and Reform Commission to declare the construction scale of the project in writing, and the project can be filed only after the approval of the Provincial Development and Reform Commission. That is to say, the project filing authority is in the Hainan Development and Reform Commission, and the Wenchang Business Environment Construction Bureau has no right to accept and file. The act of filing is beyond the statutory authority.

At the same time, Wenchang Business Environment Construction Bureau said that in order to correct the ultra vires approval behavior, the Bureau had cancelled the project filing on the online approval and supervision platform of investment projects on the afternoon of September 12, 2025. On the same day, Hainan Shengshi Clean Energy Co., Ltd. was informed of the situation by telephone, and on October 10, 2026, the company was formally informed in writing that

the filing of the above-mentioned "Shengshi Wenchang Overseas Chinese Farm 100MW Fishing-Photovoltaic Complementary + Energy Storage Photovoltaic Power Generation Project" had been formally invalidated. And the filing documents can not be used as the basis for the company to handle all the formalities of the project.

At the same time, Hainan Shengshi Clean Energy Co., Ltd. is required to re-declare the project to the Hainan Development and Reform Commission , which has the authority to file.


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