i Overview of renewable energy project development in Japan
When disaster struck the Fukushima Daiichi Nuclear Power Plant following the Great East Japan Earthquake on 11 March 2011, there were 54 nuclear reactors operating in Japan and generating about one-third of Japan's power.2 As of 1 December 2017, it had been decided that 15 of those nuclear reactors should be decommissioned, and at present only five are still operating.
Addressing the need to secure alternative energy sources to replace nuclear power, the Japanese government has strongly supported the construction of power plants utilising renewable energy sources, including solar power, wind power, hydroelectric power, geothermal heat and biomass power.
On 26 August 2011, the Japanese government enacted the Special Measures Law concerning the Procurement by Electric Power Companies of Renewable Energy Electricity (Act No. 108 of 2011, as amended (the Renewable Energy Law)), which introduced a feed-in-tariff (FIT) programme and set out the preliminary regulatory regime for the development of renewable energy projects in Japan.
Under the FIT programme, producers of electricity from renewable energy sources are guaranteed the purchase of their electricity by regional electric power company offtakers. Since the applicable tariff rates were established at attractive levels, particularly in the opening phases of the FIT programme (for example, at the beginning, the tariff rates for non-residential solar-based electricity were 40 yen/kWh, while they are now reduced to 18 yen/kWh), Japan has experienced rapid development of renewable energy.
As of the end of March 2017, there is a total capacity of more than 28GW of utility-scale solar, 9GW of residential rooftop solar, 3GW of wind and 2GW of biomass power stations in operation.
ii Recent amendments to the Renewable Energy Law
As of 25 May 2016, the Japanese government passed an amendment to the Renewable Energy Law, which came into effect as of 1 April 2017 (the Amendment).
Under the Amendment, a handful of modifications to the FIT programme and the legal framework of the electricity retail business have been implemented, some of which have significantly impacted the renewable energies landscape in Japan. The key details of the Amendment will be further discussed in Section III.
iii Offshore wind power projects in Japan
While a wide variety of renewable energy sources fall within the purview of the FIT programme, the renewable energy sector had largely been dominated by the development of solar power projects over the past several years and, to a lesser extent, wind power projects (both onshore and offshore).
However, in recent important trends and developments, wind power projects – and especially offshore wind power projects – have been attracting more attention in Japan.
As of 9 March 2018, a long-awaited new bill 'on promotion of use of territorial waters for offshore renewable energy generation facilities' (the New Bill) was officially approved by the Cabinet of Japan and submitted to the National Diet on the same day. The New Bill provides general regulation of the utilisation of Japanese waters to facilitate the development of offshore wind power projects in Japan.
We will describe the general scheme of the New Bill in Sections II and III.
II THE YEAR IN REVIEW – THE BOOM IN OFFSHORE WIND
The Japan Wind Power Association (JWPA), the organisation representing lots of Japanese wind power-related industries and corporations, has strong influence over wind power project policy in Japan.
In 2014, the JWPA set mid- and long-term installation goals for offshore wind power (to be specific, 0.7GW by 2020, 9.6GW by 2030, 27.9GW by 2040 and 37.0GW by 2050), and forecast that those onshore and offshore wind farms would be able to generate enough power to cover 20 per cent or more of Japan's total electricity demand in 2050.
The JWPA further confirmed that these goals were practically achievable, on the assumption that the current electricity system reform in Japan would be successfully implemented (see Section III for details of the electricity system reform).3
In response to these projections by the wind power industry, the Cabinet approved the New Bill. The documents released by the Ministry of Economy, Trade and Industry (METI) together with the New Bill indicated that the Japanese government intends to designate five promotion zones by 2030, and the meeting of the Japanese Liberal Democratic Party's members of the Houses on renewable energy promotion confirmed that this is not the maximum number of promotion zones.
In addition, according to the New Bill, there is no limitation on the capacity to be generated in these zones.
The JWPA has requested a commitment from the Japanese government to develop 10GW of offshore wind power by 2030, but the Japanese government has not responded so far. Therefore, the actual Japanese target capacity for offshore wind is not clear at present.
III THE POLICY AND REGULATORY FRAMEWORK
i The policy background
The accident at the Fukushima Daiichi Nuclear Power Plant revealed the problems of Japan's power supply system and prompted the Japanese government to initiate a reform of the electricity system.
The electricity system reform efforts began in 2015 with the objectives of (1) securing a stable electricity supply; (2) suppressing electricity rates by lowering the costs and optimising the supply of electricity to the maximum extent possible; and (3) providing various options for users and expanding opportunities for business entities.
These efforts led to the amendment of the Electric Business Act (Act No. 170 of 1964, as amended (EBA)) in April 2016, which fully liberalised the Japanese retail electricity market and supported more construction of renewable energy power plants.
We will describe below the details of the current regulatory framework relating to the renewable energy sector in Japan following the electricity system reform and the amendment of the EBA. In particular, we will introduce the general scheme for offshore wind development in Japan in view of the predicted importance of its role in the country's renewable energy market.
ii The regulatory framework
Renewable energy business outline
The principal government participants in Japan's renewable energy sector are the METI and its affiliated agency, the Agency for Natural Resources and Energy; the Renewable Energy Law is also administered under the supervision of the METI.
The Renewable Energy Law provides that when a person desires to generate electricity by means of a renewable energy source certain practical and legal steps must be observed.
The process for establishing a renewable energy project in Japan involves a number of key steps. While the details may change depending on the specific circumstances of a given project, the general contours may be summarised as follows.
Incorporation of business entity4
As the first practical step in establishing a renewable energy project, the sponsors of the project typically incorporate an entity to function as the holder of the project rights, including an appropriate authorisation from the METI (the METI Authorisation), as well as appropriate land ownership or lease rights, module ownership or lease rights and other rights relevant to the carrying on of electrical generation business. Incorporation of the desired form of legal entity for the project company is accomplished by submitting the necessary documentation to the relevant regional Legal Affairs Bureau. Generally, the process of applying to the Legal Affairs Bureau for incorporation of a legal entity requires a span of seven to 14 days for processing and acceptance.
Selection of project site
A proper site must be selected for the installation of the energy generation equipment. In general, appropriate sites for energy generation projects are selected such that they do not overlap with any land designated as agricultural land, forest reserves, culturally sensitive land or national or quasi-national park.
This is the case because surveying, inspection and possible redesignation of these types of land is an uncertain, time-consuming and expensive process.
Due diligence should be carried out over any land of interest for a proposed project, including obtaining a certified copy of the applicable land register to check the registered ownership and whether there are any registered interests such as mortgages, leases or easements that may affect the project.
Then the project company enters into land lease agreements or land superficies right agreements in respect of the parcels of land composing the project site, and it is recommended that the project company register the rights obtained under these agreements.
Environmental impact assessment and prior consultations
There is no national law on environmental impact assessment for solar power projects. However, there is one National Environmental Impact Assessment Law (Act No. 81 of 1997, as amended) applying to projects for 7.5MW or more wind power, 112.5MW or more biomass power, and 7.5MW or more geothermal power.
Some local governments maintain their own environmental impact assessment rules and often require the securing of various permits and licences, depending on the applicable circumstances.
The local prefectural and city offices should be contacted to confirm details of locally applicable land laws and regulations. Also, prior consultations with the relevant electric power company are customary and are conventionally expected. The consultations with the electric power company take the form of a preliminary consultation and a follow-up detailed consultation.
METI Authorisation granting process
The METI Authorisation granting process has been modified by the Amendment.
A principal reason for this aspect of the Amendment was the concern that many renewables projects that received a METI Authorisation were not actually carried through from construction to operational status.
To address this concern, the amended Renewable Energy Law provides that, after 1 April 2017, any project to be authorised must fulfil a number of additional requirements.
Previously, the METI Authorisation was required in relation to both contemplated electricity generation facilities and the methods of electricity generation used under the old Renewable Energy Law.
However, under the present regime, following the Amendment, a project must secure a grid connection agreement as a baseline requirement. Pursuant to Article 9 of the current Renewable Energy Law, a METI Authorisation is required in relation to a Renewable Energy Generation Business Plan, which must include a grid connection agreement.
A METI Authorisation already granted under the old Renewable Energy Law is deemed to be a valid METI Authorisation subject to following requirements: (1) projects granted authorisation on or after 1 July 2016 shall be given a nine-month leeway period to enter into a grid connection agreement; and (2) projects that are participating in a grid connection bidding process conducted by utilities (i.e., a process whereby several projects can share construction costs for grid connection enhancements) shall be given a six-month leeway period to enter into a grid connection agreement following conclusion of the bidding process.
Any other project is deemed to be automatically cancelled if the project has not entered into a grid connection agreement by 31 March 2017.
Because of the concern about renewables projects failing to achieve operational status, the Renewable Energy Law was amended to introduce a deadline for renewable energy projects to reach the commercial operation stage (the Commercial Operation Deadline).
If no operation commences after the Commercial Operation Deadline, a penalty will apply, in that the period during which the FIT rate would apply to the sale and purchase of the electricity generated by the authorised project (the Procurement Period) will be shortened (for example, one month's delay triggers a one month deduction from the Procurement Period).
To be specific, the Commercial Operation Deadline shall be (1) a three-year period for solar power projects with an output capacity of 10kW or more; (2) with the exception of item (4) below, a four-year period for wind power, biomass power and geothermal heat projects; (3) a seven-year period for hydroelectric power projects; and (4) an eight-year period for wind power projects and geothermal heat projects requiring an environmental impact assessment.
The Commercial Operation Deadline applies to solar power projects that enter into grid connection agreements or receive the METI Authorisation after 1 August 2016, and other renewable energy projects that receive the METI Authorisation after 1 April 2018.
Grid application and power purchase agreement
Under the present regime, upon securing the METI Authorisation, electricity generated from renewable energy sources will be sold solely to an electric power company that is allowed to conduct electricity transmission and distribution by the METI (a Souhaiden Company), rather than to an electric power company that sells electricity to consumers (an Electricity Retail Company).
Where before, a power purchase agreement (PPA) would have been executed directly with an Electricity Retail Company, now, the PPA will be executed with the Souhaiden Company, which will then be obligated to procure the means of distribution to a retail distributor of electricity.
The distribution of electricity from the Souhaiden Company to the Electricity Retail Company would then be accomplished through two possible routes: the electricity would be supplied to the Electricity Retail Company by the Souhaiden Company, acting as wholesaler; or a direct agreement would be executed between the producers of electricity and the Electricity Retail Company, with the Souhaiden Company acting only as an intermediary distributor of the electricity (and not as a wholesaler).
Construction and development of renewable energy project
Upon securing the project site and obtaining the environmental impact assessment, METI Authorisation, grid connection agreement and PPA, and creating a construction plan for the development of the project site, with appropriate notification of the construction plan to the METI, construction of the project may commence.
Before commercial operation date self-check
Before the commercial operation date (COD), a power producer with capacity of 0.5MW or more must conduct a self-check of its power equipment and report the results to the METI.
On the COD, the power producer must report the commencement of operations to the METI.
Operation of the FIT programme
Determination of procurement prices and procurement periods
The FIT rates, and the applicable Procurement Period, are determined by adopting the recommendations of an independent advisory committee – the Procurement Prices Calculation Committee – which was set up under the Renewable Energy Law and is composed of neutral third-party members appointed with the consent of both houses of the Diet.
The Procurement Prices Calculation Committee calculates its recommended prices by: (1) combining all estimated construction, operation, management and other related costs; and (2) adding a profit margin based on certain internal rates of return.
Multi-year FIT rates
Under the old Renewable Energy Law, the METI established the FIT rates on an annual basis, lasting for 15 years for geothermal and 20 years for other qualified renewable sources, with the applicable FIT rates fixed for each one-year period, one year at a time.
However, following the Amendment, it has become possible for the METI to establish the FIT rates that will apply to future periods, and it will be able to fix these rates multiple years in advance of their respective periods of applicability.
This modification of the Renewable Energy Law alleviates timing concerns and promotes the new development of business related to renewable energy sources such as wind, geothermal, hydro and biomass sources, each of which can require long lead times, including, for example, in relation to environmental assessments.
FIT auction system
For the purpose of reducing electricity procurement costs through introducing more competitive processes, the Amendment established a reverse auction system for non-residential solar power projects of 2MW or more, under which developers are able to bid on a per-kWh basis to obtain new project approvals to supply electricity from renewable energy projects up to a predetermined maximum price and maximum quota (250MW×2 in 2018).
The maximum price for the first FIT auction was 21 yen/kWh, but that was in 2017, and the price for the second and thereafter will not be disclosed (i.e., a blind auction).
Electricity retail business reform leads to more renewable energy business
As described in Section III.i, the legal framework of the electricity retail business in Japan was drastically changed by the amendment of the EBA in April 2016.
Pursuant to Chapter 1, Articles 2.1 and 2.2 of the EBA, electricity retail business is defined as 'the business of supplying electricity to meet general demand' (the Electricity Retail Business), which is a very broad definition.
A company that operates an electricity business is required to obtain a registration from the METI. However, the requirements for applying for the registration are simple: generally, an applicant company obtains the registration automatically as long as it complies with the requirements under the EBA.
Because the barrier to entry is so low, more than 400 companies have obtained registrations to operate electricity businesses as of 1 December 2017.
Although many market players have joined the Electricity Retail Business in Japan following the Amendment, the amount of electricity traded on the Japanese retail electricity market (i.e., the Japan Electric Power Exchange) only accounts for about 3.4 per cent of the total electricity traded during the period from January to March of 2017. Therefore, companies running electricity retail businesses need to establish their own power generation plants to secure stable electricity supplies in Japan.
Offshore wind development5
As described in Section I.iii, offshore wind power generation technology is becoming more mature, therefore in Japan more people are paying attention to the offshore wind market.
The general scheme for offshore wind development requires the national government to first identify appropriate areas in Japan for offshore wind development. The government will do so by working with relevant local prefectural governments and newly established bodies in each prospective development area, which will be known as 'Councils'.
Each Council will include relevant stakeholders for the development, including national ministries, local government bodies, fishery groups and academic experts.
The key role of each Council is to work to identify issues of local and national concern for offshore wind development in the development area for which it is responsible.
Following the above process, developers must then lodge competitive bids for use of the relevant offshore zone (with the bids setting out the proposed project details, including the bid price for electricity supply from the project).
The government will then closely review the bids and select bid winners based on both the proposed price and the project development plan (i.e., the bid winner is not assessed on price alone, but on both price and how well the overall development plan meets the development criteria).
The bid winner (or winners) will then have the right to occupy and use the specified general area of water for an offshore wind project for a period of up to 30 years maximum (including construction and decommissioning periods).
Therefore, while the New Bill will grant a longer occupancy period than the current prefectural rules (which are usually limited to three to five years), developers are required to compete on both price and the suitability of their development plans to secure the rights to specific offshore areas.
Special value ascribed to renewable energy
The development of renewable energy power plants has important value for protecting the natural environment. In addition, under the current environmental regulatory frameworks in Japan, renewable energy also has special properties that enable the entity generating the renewable energy (the Renewable Energy Generator) to enjoy the following benefits.
Value as J-Credit6
A certification system called 'J-Credit' in Japan offers a market for Renewable Energy Generators that reduce greenhouse gas emissions or increase greenhouse gas absorption to sell their 'credit' to third parties.
Under this system, the Renewable Energy Generator that plans or implements a project introducing energy-saving devices or managed forests can register its project by submitting its business plan to the relevant authority for certification to gain credit under the J-Credit scheme.
By monitoring the Renewable Energy Generator's business, the relevant authority will certify the amount of greenhouse gas emissions reduced by the Renewable Energy Generator's project as credit.
The Renewable Energy Generator then may sell the credit in the market by way of bilateral negotiations or an official auction held by the Japanese government.
The J-Credit market is expanding year by year. According to a report, the trading volume has reached over 0.88 million tons in 2017, which marked a new historic record.7
Value as Green Power and Green Heat Certificates8
Japan has also created an exchange market for tradable Green Power Certificates and Green Heat Certificates, through which the high environmental value of renewable energy use can be commercialised under certification schemes.
The Agency for Natural Resources and Energy and the Ministry of the Environment certify the environmental value of the Green Power, or Green Heat, Certificates and the Renewable Energy Generator can sell these and advance the environmental value of its Green Power Certification.
Value under local cap-and-trade programmes
Although no national cap-and-trade programme has been established in Japan, the Tokyo Metropolitan Government and Saitama prefecture have established local cap-and-trade programmes.
Taking Tokyo as an example,9 a business entity with facilities that consume energy of more than 1,500kl per year (the Local Cap) is obliged (1) to take measures to reduce greenhouse gas by renewing its devices and equipment, etc.; or (2) to purchase 'credit' from other entities to offset the greenhouse gas exceeding the Local Cap, in accordance with the criteria established by Tokyo Metropolitan Government.10
As with the J-Credit and Green Power and Green Heat Certificate schemes, under the local cap-and-trade programmes, the environmental value can be stripped out and sold separately in Japan.
IV RENEWABLE ENERGY PROJECT DEVELOPMENT
i Project finance transaction structures
Characteristics of project financing in Japan
Renewable energy projects in Japan are usually developed, built and operated by project companies organised in the form of a special purpose company (SPC), and the financing is handled at the level of the SPC. In Japan, there are two types of limited liability companies, both of which are commonly used as SPCs: (1) the stock company (KK);11 and (2) the limited company (GK).12
A project sponsor financially contributes to a project to be financed by providing a limited amount of equity, which is generally injected into the SPC before the debt financing is disbursed.
The debt financing is typically arranged such that it is repaid entirely from the cash flow of the project and not by means of any additional surety on the part of the sponsors of the project.
There are various lenders that may provide the debt finance to renewable energy projects in Japan, including the Development Bank of Japan Inc, commercial banks (such as Mizuho Bank, Ltd, Sumitomo Mitsui Banking Corporation and MUFG Bank, Ltd), trust banks, local banks and life insurance companies.
For renewable energy projects in Japan, the basic structuring generally involves a GK-TK structure, or simply using a GK (or KK) as an operating company.
The GK-TK structure is commonly used by Japanese and non-Japanese investors because of the associated tax benefits.
A TK13 is a contractual relationship between two entities (rather than being a separate legal entity itself), and is provided for under the Japanese Commercial Law (Act No. 48 of 1899, as amended).
A TK needs at least one TK partner or investor (which is usually a silent investor) and one TK operator (which usually takes the form of a GK).
Under the Japanese law framework, (1) the TK investor makes a financial contribution to the TK business in the form of cash or properties; (2) the TK operator conducts the TK business without disclosing the TK structure to investors or to its customers or vendors; (3) the TK investor has no power to administer the TK business and no power to dispose of the TK properties; (4) the TK investor is prohibited from representing the TK operator; and (5) the TK investor merely has a right to claim an allocation of profits or losses from the TK business.
Generally, in a common TK structure for project financing:
- the project company (which is also the TK operator) is a GK and it holds the project assets, including key contracts such as the PPA, the operating and management agreement and the engineering, procurement and construction agreement;
- the TK investor enters into an agreement with the TK operator (GK) under which the TK investor contributes funding to the GK-TK in return for a right to receive TK distributions from the TK business's profits;
- the TK operator manages the business and the TK investor has no involvement in the management decisions or day-to-day operation of the business;
- as an option, a KK acting as the service company (e.g., in relation to the asset management of the GK's operations) may provide services to the TK operator (because the GK is often an SPC and normally has no employees); and
- as another option, for the term of the project financing, the GK equity interest may be held by a special purpose bankruptcy-remote entity, which is often created and held by an independent accounting firm or trust firm in Japan.
If the TK investment is made from an affiliate that is a tax resident of a tax treaty country with a favourable other-income provision, TK distributions should be free of Japanese tax so long as there is no successful treaty shopping challenge by the Japanese tax authorities. The tax treaties between Japan and Spain, Italy and Ireland have such favourable other-income provisions, under which TK distributions should not be subject to Japanese tax.
There is limited legal theory or case law regarding the grounds on which Japanese tax authorities may challenge the validity of cross-border TK structures. However, such validity will be decided based on the factual issue, and the risk may vary depending on the roles and functions of the TK investor. Careful attention should be paid to the passive legal feature of the TK investor such that (1) it has no rights to administer or operate the TK business, and (2) it has only a passive right to receive distributions of profit from the TK business, as these are critical legal characteristics of the TK arrangement required to overcome the risk mentioned above.
ii Distributed and residential renewable energy
The accident at the Fukushima Daiichi Nuclear Power Plant revealed the vulnerability of Japan's centralised energy system. To this end, the METI, the Agency for Natural Resources and Energy and the local governments accelerated the expansion of distributed energy systems and have taken various other actions, including: (1) subsidising on-site or residential renewable energy systems and independent energy storage devices; (2) providing support for developing local biomass energy infrastructures; and (3) offering partial tax exemptions for biogasoline, etc.14
As the result, in recent years, we have seen electricity business operators start to implement on-site electricity generation services for electricity consumers, expanding diffusion of distributed energy systems in Japan.15
While, in the past, we have seen house or building owners becoming power sellers through ownership of solar panels, currently, the rooftop lease arrangement is becoming more popular. In this case, the power producer can lease the roof and install its own solar equipment on the roof, then sell power under the FIT programme.
iii Non-project finance development
Instead of using the project finance structure by borrowing from lenders for projects, several project companies in Japan have developed their renewable energy projects by (1) injecting their own funds; (2) being backed by the surety of the sponsors; (3) engaging in sole TK investment; and (4) utilising corporate finance or finance lease structures.
Among these methods, the finance lease structure is prevalent in Japan for the off-balance tax merit it provides. The following is a brief introduction to this structure.
The finance lease structure consists of a lease agreement between a lessor and a lessee and the corresponding sale and purchase agreement between the lessor (as buyer of leased equipment) and a supplier (as seller of leased equipment).
These two agreements are independent from each other but also closely related, and they have some corresponding provisions.
The lease agreement generally contains provisions such as: (1) the lessor shall purchase equipment from a seller, with the lessee designating both the equipment and the seller; (2) the lessor owns the equipment and leases it to the lessee; (3) the seller delivers the equipment directly to the lessee; (4) the lessee pays the lease payment to the lessor to compensate the purchase price of the equipment, other transactional costs and expenses incurred by the lessor; (5) the lessee shall be responsible for the maintenance and repair of the equipment; and (6) the lease agreement shall not be terminated.
V RENEWABLE ENERGY MANUFACTURING
There are various Japanese companies manufacturing renewable energy equipment such as solar modules, power conditioning systems, wind turbines and biomass boilers.
Also, given the strong market demand and low barrier to entry in the Japanese market, many foreign renewable energy equipment manufacturing companies are expanding their market share in Japan (e.g., Trina Solar, a strong solar panel producer, Huawei, which is famous for its power conditioning products, and Vestas, GE and Siemens, which are known for wind turbines).
In particular, according to the report by the Japan External Trade Organization, as of February 2017, Japanese companies do not have sufficiently a high level of technological capability to manufacture complete floating offshore wind systems, so there is high market-entry potential for foreign companies in this area.16
There are no special policies supporting the renewable energy equipment manufacturing business; however, the METI and local governments have implemented several rules to support renewable energy equipment manufacturing by providing subsidies, promoting joint research and development and offering tax exemptions.
VI CONCLUSIONS AND OUTLOOK
In July 2015, the METI approved the Long-Term Energy Supply and Demand Outlook based on the Cabinet-approved strategic energy plan, and announced the long-term energy-mix target for 2030.
This target envisages that renewable energy will account for 22 to 24 per cent of total power generation by 2030 in Japan.17 In March 2018, the METI reviewed this target and confirmed that it remains unchanged.18
Although this low target has been criticised by the renewable energy industries, we expect more renewable energy will be generated under the METI's plans.
In addition, in March 2018, it was reported that Japan's largest retail company, AEON Co, Ltd, had become the sixth Japanese company to join the RE100 initiative (following Ricoh Company, Ltd, Sekisui House, Ltd, ASKUL Corporation, Daiwa House Industry Co, Ltd and Watami Co, Ltd), and had committed to 100 per cent renewable energy consumption by 2050.19
Witnessing the fast development of this field, and the growing enthusiasm of Japanese companies for renewable energy, we believe that both domestic and overseas investment in the renewable energy industry will continue to expand in Japan.
1 Naoaki Eguchi is a partner and Naoki Ishikawa and Fei Zhou are associates at Baker & McKenzie.
3 http://jwpa.jp/pdf/2014-06dounyuumokuhyou.pdf?_sm_au_=iVV5KnKkFLLFQGNV (Japanese);
4 In addition, investment into an electricity generation business by a foreign investor is subject to the Foreign Exchange Law, under which foreign investors are required to provide notifications to both the Minister of Finance and the METI through the Bank of Japan.
5 Regarding key provisions of the New Bill, see Baker Mckenzie's Client Alert 36, New offshore wind general waters bill approved by the Japanese Cabinet (March 2018) (https://www.bakermckenzie.co.jp/wp/wp-content/uploads/ClientAlert_180316_Renewable-Energy-No.36_New-offshore-windbill_E.pdf).
10 http://www.kankyo.metro.tokyo.jp/climate/large_scale/trade/index.files/torihiki_nyuumon_1.pdf (Japanese).
11 Kabushiki kaisha.
12 Godo kaisha.
15 http://www.enecho.meti.go.jp/committee/council/electric_power_industry_subcommittee/001_005/pdf/005_000.pdf (Japanese).