a strong renewable energy directive for 2030 a bee ... · furthermore, the possibility to use new,...

A Strong Renewable Energy Directive for 2030 A BEE consultation response February 2016

Response to the Renewable Energy Directive consultation

2

2

1. To what extent has the RED been successful in helping to achieve the EU energy and climate change objectives?

Very successful Successful Not very suc-cessful Not successful No opinion

X

Comments: To what extent did implementation measures for the RED as well as external factors (technological development, financial crisis, security of supply concerns and related market interven-tions) affect the effectiveness and efficiency of achieving the objectives? Please identify and ideally also quantify the direct and indirect costs and benefits such as macroeconomic effects, competitive-ness effects, innovation, cost and cost reductions, environmental and health effects of the RED. In 2008, the European Commission and Member States were taking significant steps towards a long-term energy system transformation by setting three objectives: To attain 20% renewable energy in gross final energy consumption, 20% emissions reductions compared to 1990 levels, and 20% ener-gy efficiency compared to projected energy use in 2020. In this context, the Renewable Energy Di-rective (RED) was intended to be, and has indeed been, instrumental in driving the development of renewable energy in Europe. By providing a clear and stable legislative framework through a binding European target of 20% RE in gross final energy consumption and binding national targets for Mem-ber States, as well as binding templates for national planning and reporting (NREAPs), the RED has provided investors the certainty necessary for developing projects, innovating and minimizing tech-nology as well as overall system costs. In addition to traditional mechanisms used to enforce binding targets, such as enforcement of the legislative transposition obligation, enforcement of implementation and the obligation to prepare na-tional action plans in the form of a binding template, the Commission implements a number of other governance tools in the RED, such as the revision of the NREAPs and progress reports. This clear reporting and monitoring system was developed to ensure that Member States do not lag behind with their declared contributions. Nevertheless, target achievement has not been high on some Member States’ political agenda, with some lagging behind their interim targets for 2013/2014 (for example the Netherlands and Luxembourg1). There are also doubts as to whether all Member States, and the EU as a whole, will reach their 2020 targets2. It is also important to note that the Commission made use of reasoned opinions against some Mem-ber States (such as Belgium, Bulgaria, Finland, Hungary) for not transposing the directive, as well as invoking infringement proceedings against Spain, Poland and Ireland for failing to properly apply the substantive provisions of the directive. Over the years, the RED has served as a solid legislative basis for creating a level playing field for renewable energy by making use of national support mechanisms and clear regulations regarding transparency of costs and administrative procedures, as well as by introducing sustainability rules. This has led to innovations and, together with other factors, massive cost reductions. For example, PV module costs have fallen by 60% in just three years and, in Germany, overall system costs by around 40% over the last three years. The price of solar is expected to continue to fall by at least a 1 Keep on Track! “Are EU Member States on track?”, 2015. Available at: http://www.keepontrack.eu/keeping-track/. 2 Keep on Track! “EU Tracking Roadmap 2015”, 2015. Available at: http://www.keepontrack.eu/contents/publicationseutrackingroadmap/eu_roadmap_2015.pdf.


3

3

third in the coming years3. Not only did the RED and national support mechanisms implement econ-omies of scale leading to technology development, but they also increased competitiveness. For example, the German market, dominated by four large players (with a market share of 80% of power generation4), became more competitive, with almost 50% of installed power capacity in the hands of private individuals and communities5. This has led to increased public acceptance in contrast to other Member States. Further indirect benefits of the RED include the reduction of GHG emissions and reduced fossil fuel imports. According to a report released by the EC Joint Research Centre, after replacing fossil fuels with renewables, EU emissions of GHGs fell by 8.8% over the three years up to the end of 20126. A second report by NewClimate Institute puts the figure for fossil fuel import savings for the EU, China and the U.S. together at $500 billion yearly if they would switch to 100% renewable energy7. Last, but not least, the most important indirect benefits are the creation of a modern and future-oriented indus-try, added value at European, national and local levels, as well as jobs and acceptance.

2. How should stability, transparency and predictability for investors be ensured with a view to achieving the at least 27% renewable energy target at EU level? Please indi-cate the importance of the following elements:

Very im-portant Important Not very

important Not im-portant

No opinion

Forward looking strategic plan-ning of RES development is required by EU legislation

X

Best practice is derived from the implementation of the existing Renewable Energy Directive

X

Regional consultations on re-newable energy policy and measures are required

X

Member States consult on and adopt renewable energy strate-gies that serve as the agreed reference for national renewable energy policies and projects

X

The Commission provides guid-ance on national renewable energy strategies

X

3 Cleantechnica “Solar Costs Will Fall Another 40% In 2 Years. Here’s Why, 2015. Available at: http://cleantechnica.com/2015/01/29/solar-costs-will-fall-40-next-2-years-heres/. 4 Bpb “Die Großen Vier”, 2013. Available at: http://www.bpb.de/politik/wirtschaft/energiepolitik/152780/die-grossen-vier. 5 AEE “Installierte Leistung Erneuerbarer Energien nach Eigentümergruppen in Deutschland 2012”, 2013. Available at: http://www.unendlich-viel-energie.de/mediathek/grafiken/buergerenergie-eigentuemerstruktur-und-installierte-leistungen-der-anlagen. 6 JRC Science for Policy Report „Renewable Energy in European Union for climate change mitigation: Greenhouse gas emis-sions savings due to renewable energy (2009-12), 2015. 7 NewClimate Institute „Assessing the missed benefits of countries‘ national contributions“, 2015.


4

4

Box: Any other view or ideas? Please specify. What are the lessons from the RED (mandatory na-tional targets, national plans, progress reports etc.)? A timely, clear and stable framework is essential to ensuring stability for investors. The European Commission’s communications on the Energy Union and the governance system for 2030, as well as the recent Council Conclusions on the same issue, lay the necessary foundation but fail to flesh out the main details. Over the next years, these details, (such as the ambition of national contributions, the design of national climate and energy plans, as well as clarifying the consequences of non-achievement), will have to be discussed and agreed upon to ensure that they offer maximum invest-ment certainty and do not halt the development of renewable energy deployment in the EU. As investors are currently operating in a regulatory vacuum, (until now only six Member States have declared post-2020 renewable energy targets), BEE calls on the European Commission to set indi-vidual indicative benchmarks for Member States to help guide them in defining their contributions. These should be included in the Renewable Energy Directive. Furthermore, it is paramount that the national climate and energy plans, as well as the monitoring system, are anchored in legislation (preferably in the Renewable Energy Directive). In the absence of binding national goals, these plans are necessary for providing investment certainty and ensuring that the European goal is achieved. Embedding development of the plans into the legislative procedure will also ensure their legitimacy, as the European Parliament and stakeholders will be fully involved in the process. National plans should include concrete national contributions, technology-specific deployment vol-umes, indicative trajectories with interim targets, as well as indicative trajectories with interim targets for all three sectors – power, heating and cooling, and transport. As regards monitoring, the Renewa-ble Energy Directive should, in addition to progress reports, allow for more oversight of the European Commission over Member States’ progress. It should also allow the Commission to intervene in case Member States make counter-productive changes to their regulatory or market framework, via policy recommendations, for example. The European Commission must ensure that Member States cannot amend their plans at will and negatively impact target achievement. As the renewable energy target of at least 27% RE at European level has a binding character, it is also important that Member States’ national contributions are clear and that their sum meets or ex-ceeds the target. This is why the consequences of non-achievement have to be clearly and timely defined. Member States that achieve their national contribution on their own should be allowed to opt-out; the ones that don’t should be incentivized to meet their national contribution via a specially de-signed financial instrument. Furthermore, the possibility to use new, redesigned cooperation mecha-nisms should be maintained. A European “gap-filling” instrument should be included in the RED, as should an EU-wide “gap-avoiding” instrument. The first could be of a financial nature and would involve the use of already existing funds, such as the structural funds. Member States would have access to funds specifically earmarked for the development of renewable energy. This would lead to competition between Mem-ber States and ensure the achievement of the binding European goal. The “gap-avoider” would also lead to target achievement, only by addressing Member States’ ambition gap when deciding on their contribution, i.e. at an earlier point in time. In order to enhance predictability of investments in the RE sector, it is crucial – besides having a long-term decarbonisation strategy – to have binding targets and milestones for the years 2020, 2030, 2040, 2050. The expansion of renewable energy is one of the central instruments for decarbonizing the entire energy system and also contributes significantly to the achievement of our climate targets. In


5

5

a system that increasingly builds on volatile renewables, there is a need for gradual replacement of inflexible systems. The intelligent interconnection between renewable energy and interruptible loads (i.e. power-to-X solutions) guarantees security of supply, reducing the need for conventional power plants. In order to support the market and system integration of renewables, as well as in order to cut emis-sions, use of renewable electricity in the heating, transport and industrial sectors plays an essential role. With increasing expansion of volatile renewable energy, converting electricity into storable forms of energy (power-to-X) with the highest possible efficiency is crucial. The aim is to achieve full integra-tion of renewable electricity generated in the power system and to render it usable in all areas. Cou-pling the electricity, heating and cooling, and transport sectors, which were previously largely inde-pendent, with the respective end consumers is the next logical step in the process of transforming the European energy system. To initiate sector coupling and use renewable electricity for heat, mobility and industry, the creation of interfaces between the sectors is essential. The aim is to allow companies – such as operating com-panies, utilities or industrial investors – the economical use of any renewable electricity that cannot be fed into the grid in power-to-X solutions.

3. Please rate the importance of the following elements being included in Member States' national energy and climate plans with respect to renewable energy in ensur-ing that the plans contribute to reaching the objectives of at least 27% in 2030.

Very important Important Not very


No opinion

Long term priorities and visions for decarbonisation and renewable ener-gy up to 2050

X

In relation to national/regional natural resources, specific technology rele-vant trajectories for renewable energy up to 2030

X

Overview of policies and measures in place and planned new ones X

Overview of renewable energy trajec-tories and policies to 2050 to ensure that 2030 policies lie on the path to 2050 objectives

X

Qualitative analysis X Trajectories for electricity demand including both installed capacity (GW) and produced energy (TWh)

X

Measures to be taken for increasing the flexibility of the energy system with regard to renewable energy pro-duction

X

Plans for achieving electricity market coupling and integration, regional measures for balancing and reserves

X


6

6

and how system adequacy is calcu-lated in the context of renewable en-ergy The Council Conclusions on the governance system of the Energy Union for 2030 state that the plans have to be based on “existing building blocks in climate and energy policy” and maintain “the estab-lished level of substance and data quality”. We thus conclude that implementing a clear indicative trajectory with interim targets to provide an overview of the renewable technologies to be deployed is paramount to complying with the provisions stated in the Conclusions. Furthermore, these trajectories must be embedded within credible indicative renewable energy trajectories and policies for 2030 across all three sectors, also including interim targets. This also links current development to the more long-term goals of decarbonisation by 2050. What is more, other policies in the energy sector should complement and not undermine the strength of the renewable energy policies. Thus, capacity markets and/or the existence of poorly designed tendering systems cannot, for example, coexist with meaningful renewable energy policies. A robust Energy Union is based on the transformation of our current centralized and inflexible energy system into a decentralized and flexible one. This requires placing variable renewable energy at the centre of the system and allowing and incentivizing the existence of flexibility options (such as flexible renewa-ble energy generation, storage, DSM, grid expansion, etc.). Electricity market design will play an important role as the counterpart of a strong governance sys-tem. Flexible and interconnected national markets, which deliver a functioning internal energy market, are of the essence. The new energy market should allow for price peaks, both positive and negative, as well as include flexibility options. This should be complemented by functioning and modern bal-ancing markets, where renewable energy and flexible technologies, such as storage, can compete on a level playing field. Last but not least, renewable energy components of the national climate and energy plans should be rooted in legislation to ensure their legitimacy. This would require their inclusion in the Renewable Energy Directive.

4. What should be the geographical scope of support schemes, if and when needed, in

order to drive the achievement of the 2030 target in a cost-effective way?

Harmonised EU-wide level support schemes Regional level support schemes (group of Member States with joint support scheme)

National support schemes fully or partially open to renewable energy producers in other Mem-ber States

X Gradual alignment of national support schemes through common EU rules National level support schemes that are only open to national renewable energy producers

Currently there is no need to introduce harmonized EU-wide support schemes, as national support schemes have been converging more and more over the past years. Moreover, such schemes would not bring any benefits in terms of effectiveness and cost-efficiency. First of all, not only do national markets and the degree of technological maturity differ from one Member State to the other - so do refinancing conditions, prequalification requirements and the taxation system. Introducing an abstract general rule accounting for all these differences between 28 Member States seems an impossible task. Secondly, there is an increasing need for revised remuneration mechanisms for renewable en-ergy, in light of increasing shares of renewable energy in our energy system and the incompatibility


7

7

with the current energy-only market, which needs to be further developed. Harmonizing the existing schemes does not take the long-term needs of the system into account. Bottom-up convergence of support mechanisms has already led to decreasing support levels and making renewables respond to market signals (e.g. the introduction of market premiums). Further convergence will also depend on the elimination of other barriers, such as administrative barriers or the barriers preventing the completion of the internal energy market (e.g. regulated prices, subsidies for conventional power generators). The European Commission should continue to provide guidance on this issue and push for the completion of a functioning internal energy market. As regards regional level support schemes, we believe that introducing regional renewable energy targets backed-up by support schemes will only replicate the difficulty of breaking down the EU bind-ing target of 27% RE into concrete commitments and ensuring target achievement at another level. This would only add more uncertainty for the investors already struggling with unclear implementation of EU provisions. If the goal is to increase regional cooperation, this could, for example, be done via common auctions of two neighbouring Member States open to projects in both countries. Necessary requirements for this would be a level playing field between project sites and an existent physical transfer of electricity. If Member States were required to open their support schemes to generation coming from other Member States this would only increase uncertainty, pose serious risks in terms of public acceptance and destabilize the regulatory framework already in place. This, in turn, would risk failure to meet the binding 2030 renewable energy target. As for the use of sustainable renewable fuels in transport, however, the status quo, (where sustaina-ble renewable fuels from all Member States are eligible for EU-wide support via renewable energy obligations – biofuel quotas), should be upheld. Renewable energy obligations differ significantly from direct price support schemes as they refer to the consumption of renewable energy and not produc-tion in a certain Member State.

5. If EU-level harmonised /regional support schemes or other types of financial support to renewable energy projects would be introduced:

• What hinders the introduction at the EU wide and/or regional scale? • How could such mechanism be activated and implemented? • What would be their scope (what type of projects/technologies/support mechanisms) could

be covered? • Who would finance them? • How could the costs of such measures be shared in a fair and equitable way?

There is currently no need to introduce harmonized or regional support schemes, as the markets in Europe and developmental stages of various technologies are very different. Although wind and solar power have reached maturity and cost competitiveness in most markets, there are still barriers block-ing their full deployment – be it the power of incumbents, high capital costs that increase the need for support, or public acceptance. Furthermore, most Member States are lacking a robust grid expan-sion, just as the European Union is lacking sufficient interconnection capacity. It is also important to note that, in recent years, we have witnessed an increased convergence of national schemes with Member States learning from each other’s best practices. Regional coopera-tion in areas such as market integration of renewables and market design are also picking up speed,


8

8

for example through cooperations like the one in the Pentalateral Forum. We encourage the Europe-an Commission to incentivize such initiatives and to set the necessary foundation for more regional cooperation and exchange of best practice and information. Also central is the involvement of stake-holders. Nevertheless, in order to reach the binding target of at least 27% renewable energy in gross final energy consumption at European level, and in the case of Member States’ national contributions not adding up to this binding pledge or countries falling behind their stated contribution, the European Commission should have the option to intervene and correct these developments. The mechanism required to ensure target achievement should be designed in a timely fashion and be anchored in legislation, to ensure its legitimacy and provide investment certainty. An efficient mechanism to avoid failing to meet the target might be an EU-wide financial support in-strument via an already established EU-level financing facility, such as the structural funds. This in-strument should be discussed and agreed upon with Member States, and should specifically target renewable energy projects and facilitate delivery of the binding target.

6. The current Renewable Energy Directive gives Member States the possibility to enter into various cooperation mechanisms (statistical transfers, joint projects and/or joint support schemes). Please expand on the possible new legislative and non-legislative measures that could be introduced to foster the development of cooperation mecha-nisms in the period beyond 2020.

The mid-term evaluation of the Renewable Energy Directive concluded that national targets for 2030 would be a precondition towards the effective use of cooperation mechanisms beyond 2020. Without national targets, there really are no strong incentives to cooperate. This raises questions about the continuing existence of cooperation mechanisms during the period up to 2030. The lack of clarity of the governance framework is at odds with the European Commission’s and the Member States’ desire to increase regional cooperation. We therefore call on the European Commis-sion to set individual indicative benchmarks for Member States to help guide them in defining their contributions. Member States that cannot or do not want to achieve their contribution nationally could make use of the new, redesigned cooperation mechanisms, in turn increasing the chances of collec-tively meeting the binding target of at least 27% RE in gross final energy consumption. The German renewable energy industry also encourages the European Commission to incentivize initiatives such as the Pentalateral Forum and to set the necessary foundations for increased regional cooperation and exchange of best practice and information. Also central is the involvement of stake-holders.

7. The use of cooperation mechanisms has been limited to date. Which of the below fac-

tors do you consider important in explaining the limited recourse by Member States to cooperation mechanisms so far?



No opinion

Unclear legal provisions X Administrative complexities X Lack of cost-effectiveness / uncertain benefit for individual X


9

9

Member States Government driven process, not market driven X

Member States reluctant to see their taxpayers/ consumers' money used for investments outside their country

X

There is extensive documentation concerning the limited use of cooperation mechanisms under the 2020 framework. To our knowledge, the main reason as to why the use of cooperation mechanisms has failed to attract Member States is the latter’s uncertainty regarding the individual benefits they would reap from cooperating. Further reasons for this have been difficulties in predicting whether the 2020 national binding goals can be achieved solely by the nation itself, (especially with the trajectory rising more steeply towards the end of the decade), and difficulties in communicating the choice of using a cooperation mechanism to the public, as this would imply financing renewable energy devel-opment somewhere else. Most countries have chosen to achieve their goals nationally, and have reaped the benefits of do-mestic renewable energy, such as tax income, infrastructure development, and jobs. This has also led to increased public acceptance, especially in Germany where almost 50% of installed renewable power capacity is in the hands of private individuals and communities. A further challenge has been the design of cooperation mechanisms, as countries have divergent renewable energy potential and technology preferences, as well as different power market regulation and design. Nevertheless, with increased convergence of support schemes and the need to collec-tively deliver on the 27% target via regional cooperation, new and redesigned cooperation mecha-nisms might experience increased interest from Member States.

8. How could renewable electricity producers be fully or partially eligible for support in another Member State? Which elements would you include in a possible concrete framework for cross-border participation in support schemes? Any other considera-tion? Please explain.

The German renewable energy industry believes that opening Member States’ support mechanisms to generation from other Member States risks undermining the existing regulatory framework, thus endangering the achievement of both the 2020 and the 2030 targets by significantly increasing the risk in terms of public acceptance (not benefitting from job creation and added value). In addition, renewable electricity producers are not the main stakeholders affected by opening up of support schemes, as a large share of power is being sold directly. Direct marketers are the ones entering into contracts and bearing responsibility for their balancing zone. In principle, opening up of support schemes should only be possible on a voluntary basis and if there is a physical flow of electricity to the Member State providing the support. The physical flow aspect is essential, as renewable energy systems are also required to provide ancillary services.

9. Please assess what kind of complementary EU measures would be most important to ensure that the EU and its Member States collectively achieve the binding at least 27% EU renewable energy target by 2030:


10

10



No opinion

EU-level incentives such as EU-level or regional auctioning of renewable energy capacities

X

EU-level requirements on mar-ket players to include a certain share of renewables in produc-tion, supply or consumption

X

EU-level financial support (e.g. a guarantee fund in support of renewable projects)

X

EU-level support to research, innovation and industrialisation of novel renewable energy technologies

X

Enhanced EU level regulatory measures X

The German renewable energy industry believes that national binding targets are the most effective and cost-efficient way of achieving the EU renewable energy target of at least 27% RE in gross final energy consumption. In the absence of national targets, the European Commission should define a clear course of action based on national contributions that add up to the binding target as part of the governance system and via rule of law (i.e. the Renewable Energy Directive). For example, the Commission could set individual indicative benchmarks for Member States to help guide them in de-fining their national contributions. Through a dedicated dialogue between the Commission and Member States, the sum of the national contributions should meet or exceed the binding EU target. In this context, the European Commission should push for increased regional cooperation and redefine the content and the use of cooperation mechanisms. If the sum of the national contributions does not meet the target, the Commission should make use of a dedicated, timely defined and regulatory EU back-up instrument to meet the target in a cost-effective manner. The BEE does not support the introduction of EU-wide auctioning schemes or quo-ta systems as “gap-fillers”. First of all, designing such an instrument would be an administrative nightmare and would barely account for the various Member States’ differing markets and maturity of technologies. Secondly, an EU-wide system would risk interfering with the functioning and the suc-cess of this instrument at national level. Thirdly, it would increase policy focus upon the power sector, instead of concentrating on all three sectors equally, especially considering that the heating and cool-ing, and transport sector are already lagging behind. It is important to note here that there should be separate discussions for each of the sectors, as an EU-level requirement for market players to in-clude a certain share of renewables in production, supply or consumption would be relevant for the transport sector but not the power sector. A better approach would be to enable an efficient EU-wide “gap-filler” by earmarking already existing financial support, such as the structural funds, specifically for the development of renewable energy projects. Member States looking to develop renewable energy projects could do so by using these funds to ensure that the binding European goal is attained.


11

11

10. The Energy Union Framework Strategy sets the ambition of making the European Un-ion the global "number one in renewables". What legislative and non-legislative measures could be introduced to make/strengthen the EU as the number one in re-newables? Has the RED been effective and efficient in improving renewable energy industrial development and EU competitiveness in this sector?

The EU has played a central role in delivering the Paris deal, a historic treaty signed by 195 govern-ments. Now it needs to translate its leadership into domestic policy that fosters a vibrant home mar-ket with clear growth perspectives for renewable energy and meets the ambitious COP21 goals. Although the Energy Union Framework Strategy strives to make the European Union the global “number one in renewables”, the reality of this unfortunately remains distant. According to the Frank-furt School FS-UNEP Collaborating Centre, China was the largest investor in new renewable energy systems in 2014, investing $83.3 billion. Europe stayed at second place with $57.5 billion, closely followed by ASOC (excluding China and India) and the United States. In 2014, investment in China surged by 39%, whilst in Europe it was up less than 1% from 2013. As regards the level of ambition, China recently announced that it wants to use solar power to gener-ate 150 to 200 GW of electricity by 2020, as well as lift its wind power targets to 250 GW by the same year8. Considering that it already held first place in total renewable power generation capacity in 2014, followed by the US, it is clear that the gap between China and the European Union will only get bigger. In Europe, renewable energy investment has been driven by stable and clear investment conditions. These include a strong Renewable Energy Directive, with national binding goals for Member States and national support schemes. They have been instrumental in creating a home market, which needs to be preserved. However, as the new Governance Framework 2030 threatens their existence, un-certainty is going to rise. What we need is credible and reliable policies in all EU Member States that increase the share of renewables as is required by the existing RED, attaining at least 27% by 2030. Yet, retroactive changes in key European markets have severely tarnished the EU’s reputation as a safe and attractive renewable energy investment hub. It is therefore important to highlight that the 2020 targets, and the legal consequences of not achieving them, remain firmly in place, and that, leading up to 2030, investors require a similarly robust governance structure and directive. Stable regulatory frameworks at both EU and national level remain crucial for sustaining EU’s global leader-ship. Furthermore, increasing security of supply through renewables is crucial for the EU to fulfil its goal of becoming “number one in renewables”. Opening up energy markets, increasing grid expansion, en-hancing sector coupling and developing storage technologies are key, as are enabling the participation in the market and competition between flexibility options, renewables and new flexibility technologies.

11. How would you rate the importance of the following barriers for consumers to pro-duce and self-consume their own renewable energy?

Very Important Not very Not im- No

8 The New York Times „China Rises Its Targets For Renewable Energy“, 2015. Available at: http://www.nytimes.com/interactive/projects/cp/climate/2015-paris-climate-talks/china-raises-its-targets-for-renewable-energy.


12

12

important barrier

barrier important barrier

portant barrier

opinion

Self-consumption or storage of renewable electricity produced onsite is forbidden

X

Surplus electricity that is not self-consumed onsite cannot be sold to the grid

X

Surplus electricity that is not self-consumed onsite is not valued fairly

X

Appliances or enabler for thermal and electrical storage onsite are too expensive

X

Complex and/or lengthy adminis-trative procedures, particularly penalising small self-consumption systems

X

Lack of smart grids and smart metering systems at the consum-er's premises

X

The design of local network tariffs X The design of electricity tariffs X Today, self-consumption of renewable energy is essential for the cost-efficient operation of PV sys-tems. Notably it is commercial and industrial businesses that are using self-consumed solar power or take part in new direct marketing schemes. For new projects in the residential sector the consump-tion of self-produced PV power is also essential for the cost-efficient operation of the system. However it is not only commercial benefits that are the reason for partial or full self-consumption. Self-consumption and direct supply concepts are important elements that go towards increasing the flexibility of supply in the context of redesigning the energy market. Power generation’s increasing volatility requires an increasingly flexible demand side: For example, businesses owning a renewable energy power plant can, depending on the market signals, buy power, change their self-consumption pattern or adapt their production. Self-consumption also has added value for the power grid. Self-consumption can render grid opera-tion more reliable and cost-efficient by reducing power peaks, as well as regulating frequency through PV and battery storage systems. Another aspect of self-consumption is its importance for energy cooperatives. In Germany, the devel-opment of decentralized projects using PV systems or CHP, where power is produced and consumed locally, has been legally and economically hampered. These sorts of projects, building renewable power plants that produce and deliver locally without the use of the grid, are some of energy coopera-tives’ most important business models. Furthermore, they embody one of these entities’ most signifi-cant business concepts: To deliver renewable power to their members from their own plant at an attractive price. In most cases, it is not economically viable to deliver the power produced by a PV system to the members of the cooperative that own it. Therefore, the rollout of smart meters for very small consumers and renewable power plants, which is being pushed forward by legislation, is in opposition of this economic rationale.


13

13

As regards surplus electricity, opinions on its value need to be revised. In Germany, both policy mak-ers and large utilities consider self-consumption and surplus electricity to have a lower economic value than paying grid charges. This is an antiquated point of view, as such projects actually contrib-ute to an increase in both public acceptance in local communities and regional value creation, as well as offering individuals one of the easiest ways to increase their knowledge about renewable energy and appreciate the benefits of these technologies.

12. In general, do you think that renewable energy potential at local level is:

Highly under-exploited X Under-exploited Efficiently / fully exploited Over-exploited (i.e. beyond cost-effectiveness) No opinion

Box: Other? Please explain. Has the RED been effective and efficient in helping exploiting the re-newable energy potential at local level? It is very difficult to formulate an answer that would incorporate all sectors – the power, heating and cooling, and transport sectors, as well as all Member States. Nevertheless, we believe the full poten-tial of renewable energy is far from being effectively used. This also raises problems for the post-2020 period, as the unclear governance framework risks failing to tap into a lot of potential. National binding goals have, at least in Germany, had a positive effect and have driven renewable energy development at both the Länder as well as the local level. In the absence of national goals, other means will be necessary to incentivize an increased RE deployment. In Germany, national goals have been translated into regional and local goals and strategies for the development of renewables. This could be regarded as a best practice example. The European Commission could encourage other Member States to make use of such instruments, for example by requiring administrations to include them in their national plans.

13. How would you rate the importance of the following barriers that may be specifically

hampering the further deployment of renewable energy projects at the local level (municipalities and energy cooperatives):

Very im-portant barrier

Important barrier

Not very important

barrier

Not im-portant barrier

No opinion

Lack of support from Member State authorities X

Lack of administrative capacity and/or expertise/ knowledge/information at the local level

X

Lack of energy strategy and plan-ning at local level X

Lack of eligible land for projects and private property conflicts X


14

14

In Germany, one of the main obstacles to local level renewable energy projects is the introduction of mandatory auctioning, beginning 2017. This system poses new barriers to the development of pro-jects by energy cooperatives, especially for wind energy. By refusing to fully use the so-called de minimis rule of the European Commission’s Guidelines on State aid for environmental protection and energy 2014-2020, the German administration is de facto hindering competition. Energy cooperatives develop small projects in their regions one at a time, and are therefore not able to divide the project costs and risks between different simultaneous projects. They thus stand to lose between €189,000 and €315,0009 for each wind power plant that does not win the bid, meaning that energy coopera-tives will no longer be able to participate in the energy market. The significant advantage energy cooperatives have is that they produce electricity from renewable energy sources to cover local demand and thus can easily integrate green power into the energy system. Their projects may not have lower generation costs, but they result in far lower system costs. In Germany, as in other Member States, the administration does not take account of this specific cost advantage of community energy projects. Instead of supporting the direct use of renewable power at local level, the German administration is rendering these concepts infeasible. Three aspects are to be noted in this context: Firstly, all specific cost advantages resulting from local-ly generated and consumed green power, such as lower grid fees, have been repealed or refused for community energy projects. Secondly, administrative requirements hinder the smooth realization of concepts focusing on the direct use of locally generated electricity. Last but not least, the cost struc-ture of the energy system, especially the renewable energy surcharge and grid fees, penalize organi-zations that use power to heat installations and electric storage for balancing fluctuating wind and PV energy. Community energy projects are one of the best means for activating flexibility options, but they are burdened by financial obligations. This has a negative impact upon their economic feasibility and leads to a paradoxical situation: While there is strong political support for unlocking balancing op-tions, existing legislation prevents precisely the best solutions to target them. Acceptance is another strong suit of community energy projects, as it is easier for these projects to access available areas, and because they also benefit from the support of the public.

14. Please rate the appropriateness of stronger EU rules in the following areas to remove barriers that may be specifically hampering the further deployment of renewable en-ergy projects at the local level:

9 Numbers are based on BMWi ”Marktanalyse – Windenergie an Land“, 2015, p. 4 and Fachagentur Windenergie an Land ”Dauer und Kosten des Planungs- und Genehmigungsprozesses von Windenergieanlagen an Land“, 2015, pp. 2-3. The aver-age installed capacity of a new wind power plant in 2014 in Germany: 2.7 MW, the average costs from pre-analysis to the defini-tive permit according to the Federal Immission Control Act: 70-115 €/kW planned installed capacity.

Difficulties in clustering projects to reach a critical mass at local level X

Lack of targeted financial re-sources (including support schemes)

X

Negative public perception X


15

15

Very ap-propriate Appropriate Not very

appropriate Not appro-

priate No

opinion Promoting the integration of renewable energy in local infrastructure and public ser-vices

X

Supporting local authorities in preparing strategies and plans for the promotion of renewable energy

X

Facilitating cooperation be-tween relevant actors at the local or municipal level

X

Facilitating access to targeted financing X

EU-wide right to generate, self-consume and store re-newable electricity

X

Measures to ensure that sur-plus self-generated electricity is fairly valued

X

Harmonized principles for network tariffs that promote consumers' flexibility and minimise system costs

X

The German renewable energy industry believes that, in particular, the EU-wide right to generate, self-consume and store renewable electricity must play an important role in the future energy market. Unfortunately, we see this right as being endangered by an increasing financial burden (e.g. the re-quirement to pay the renewable energy surcharge for PV power in the area of single-family housing). Another important aspect is the successful activation of balancing options such as local electrical storage or power to heat installations. This should be implemented via a redesign of the electricity costs that these options are currently subject to. The European Commission could offer Member States guidance in this regard. The Commission could also play a role in clarifying financing issues at local level. By requiring Mem-ber States to include local strategies and goals in their national plans, as well as cooperation be-tween levels regarding the development and financing of RE projects, the Commission would remove the barriers hampering renewables’ development at local level.

15. Should the current system for providing consumers with information on the sources of electricity that they consume be further developed and improved?

Box: If not, why? If yes, how? Should the current Guarantees of Origin (GO) system be made the mandatory form of information disclosure to consumers? Should other information, such as e.g. CO2 emissions be included? Should it be extended to the whole energy system and include also non-renewable sources? Other ideas? To what extent has the current GO system been successful in providing consumers with information on the sources of electricity that they consume?


16

16

BEE believes that it is necessary to provide information on the origin of all energy sources as well as costs, (including external costs), in terms of transparent criteria.

16. Please rate the importance of the following barriers in hampering the deployment of renewable heating and cooling in the EU:

Very im-portant barrier

Important barrier

Not very important

barrier

Not im-portant barrier

No opinion

Real or perceived incoherence in existing EU policies (such as RED, EED and EPBD)

X

Lack of administrative capacity and/or expertise/ knowledge/information at the national and local level

X

Lack of energy strategy and planning at the national and local level

X

Lack of physical space to de-velop renewable heating and cooling solutions

X

Lack of requirements in build-ing codes and other national or local legislation and regulation to increase the share of energy from renewable sources in the building sector

X

Heating and cooling equipment installers lack sufficient knowledge or information to offer renewable energy alterna-tives when asked to replace fossil fuel heating and cooling equipment

X

Lack of targeted financial re-sources and financing instru-ments

X

Lack of definition and recogni-tion of renewable cooling X

Lack of electricity market de-sign supporting demand re-sponse, decentralised energy and self-consumption and thermal storage in buildings and district systems

X

Lack of mapping tools to identi-fy the resources potential at X


17

17

regional scale with local re-newable energy Lack of tools and information to compare the lifecycle costs of the various alternative heating and cooling alternatives

X

Negative public perception X Unfortunately, policy makers have consistently ignored the heating and cooling sector at both Euro-pean and national levels. The long-awaited EU Strategy for Heating and Cooling should set a clear signal of commitment towards introducing more renewable energy into the sector and dealing with the many barriers that plague it. Despite it being the task of national and local administrations to develop a heating strategy, the Euro-pean Commission should encourage the further development of municipal planning regulations. The goal would be to develop a mid-term strategy of decarbonizing the building stock, detailing the nec-essary implementation steps. In Germany, the problem of sufficient and adjusted financial support is not so much due to a lack of targeted financial resources and financing instruments but rather due to competition with fossil fuel solutions and the national financial support schemes. A more congruent structuring of financial sup-port for renewable heating and cooling technologies is needed, with a focus on overall political goals. A strong signal in regard to financing community and municipal renewable heating projects is also required. Participative ownership structures are a constituent element of the energy transformation process and are the norm when financing renewable energy power projects. In the heating and cool-ing sector there is a strong need for introducing individual warranties and allowing for public participa-tion within projects. Investing in renewable community generation capacities and network infrastructure is a capital-intensive endeavour. The amount of interest payable to banks is thus of particular importance for the economic feasibility of projects. Public administrations could introduce deficiency guarantees in order to incentivize financing and mobilize private capital for a transformation of the heating and cooling sector.

17. Please rate the most effective means of addressing these barriers and advancing the decarbonisation of EU heating and cooling supply:

Very ef-fective Effective Not very

effective Not effec-

tive No

opinion Renewable heating and cooling obligation X

Requirement for energy suppliers and/or distributors to inform con-sumers of the costs of heating and cooling and to offer renewable heating and cooling solutions

X

Requirement that all urban and municipal infrastructure upgrades X


18

18

(energy infrastructures, and other relevant infrastructure, such as sewage water, water and waste chains) make it possible and pro-mote the distribution and use of renewable energy for heating and cooling and hot water generation Measures supporting best practices in urban planning, heat planning, energy master planning, and pro-ject development

X

Criteria and benchmarks for pro-moting district heating and cooling taking into consideration the local and regional conditions

X

Nearly zero-energy building (NZEB) standards to include a mandatory minimum use of renewable energy

X

Including systematically renewable energy production in buildings' energy performance certificates

X

The promotion of green public pro-curement requirements for renewa-ble heating & cooling in public buildings

X

Heating and cooling equipment installers should present renewable energy alternatives when asked to replace fossil fuel heating and cool-ing equipment

X

Develop best practices for enter-prises, including SMEs, to integrate renewable heating and cooling into their supply chains and operations

X

Requirement to consider renewable energy alternatives in subnational, national, regional or EU security of supply risk preparedness plans and emergency procedures

X

Targeted financial measures X Box: Other? Please specify and explain. How could such measures be designed? How could they build on existing EU rules? A key issue that influences the development of renewable heating at national level is the imprecise implementation of Article 13 paragraph 4 of the Renewable Energy Directive, which states that “Member States shall, in their building regulations and codes or by other means with equivalent ef-fect, where appropriate, require the use of minimum levels of energy from renewable sources in new buildings and in existing buildings that are subject to major renovation. Member States shall permit those minimum levels to be fulfilled, inter alia, through district heating and cooling produced using a


19

19

significant proportion of renewable energy sources”. In Germany, this requirement is implemented via the Renewable Energy Heating Act, where owners of buildings that are to be newly erected are obliged to include a share of 15% renewable energy for heating purposes. Various alternative measures are also permitted, e.g. allowing the supply of energy through a district-heating network, if heating is mainly generated by renewable energy technologies, waste heat or CHP. In practice, 100% fossil generation is possible as there is no requirement that the district-heating network uses renewably generated heat. This contravenes to the clear intention of the RED to incen-tivize the use of renewable heating in district networks. It would be necessary to clarify the require-ments of Member States to use only district heating supplying a certain ambitious and increasing share of renewable energy at EU level. Stronger growth in renewable heating and cooling goes hand in hand with a stronger link to renewa-ble power generation. Surplus renewable power should be considered as a further source of renewa-ble heating and cooling. If properly incentivized, this could, together with other alternatives, be at the core of a future stable and innovative, totally clean and renewable energy system in Europe.

18. In your view, which specific evolutions of the market rules would facilitate the integra-tion of renewables into the market and allow for the creation of a level playing field across generation technologies? Please indicate the importance of the following ele-ments to facilitate renewable integration:



No opinion

A fully harmonised gate closure time for intraday throughout the EU

X

Shorter trading intervals (e.g. 15 min) X

Lower thresholds for bid sizes X Risk hedging products to hedge renewable energy volatility X

Cross border capacity allocation for short-term markets (i.e., some ca-pacity being reserved for intraday and balancing)

X

Introduction of longer-term trans-mission rights (> 3 years) X

Regulatory measures to enable thermal, electrical and chemical storage

X

Introduction of time-of-use retail prices X

Enshrine the right of consumers to participate in the market through demand response

X

Integrated and liquid intraday and balancing markets are key to efficiently operating a market with large shares of renewable energy. This is the first step towards transforming our energy system from a conventional fossil-fuelled one to one that allows and rewards flexibility.


20

20

The following points are essential for increasing integration of renewable energy, as well as participa-tion of flexibility options on the market:

• Shorter and harmonized gate closure times of max. 15 minutes before delivery • Shorter and harmonized imbalance settlement periods of max. 15 minutes • Shorter and harmonized auctions of max. 15 minutes • Smaller and harmonized bid sizes of 1 MW

Although it should be the task of Member States to further develop their intraday and balancing mar-kets, the European Commission could issue guidance entailing best practice examples to help Mem-ber States address the various challenges they might face. By helping countries to revise their mar-kets, the European Commission would be an instrumental force in terms of further integrating renew-able energy and allowing it and other flexibility options, such as storage or DSM solutions, to develop, become cost-efficient and participate in the market, thus leading to a more rapid system transfor-mation. In addition, due to the generation of variable renewable energy exceeding maximum electricity de-mand at certain times, enhancing sector coupling and the use of renewable power in the heating and cooling and the transport sector as well as in industrial processes should be pursued. At times when there is no immediate demand, surplus power can be stored for later use either within the power sec-tor or converted to another energy source for use outside of the power sector (e.g. heat, hydrogen). Curtailing renewable generation, as it is currently the case, is not sensible, neither from an economic nor an energy-related standpoint and should not be available as an option in the future energy mar-ket. The aim is to achieve full integration of the renewable energy generated in the power sector and to use it in all other areas. The key of tapping into power-to-X solutions in the future is to establish a level playing field, in particularly concerning any discrimination via taxes and duties in contrast to other forms of energy.

19. Currently, some exceptions from the standard balancing responsibilities of genera-tors exist for energy from renewable sources. In view of increasingly mature renewa-ble generation technologies and a growing role of short-term markets, is time ready to in principle make all generation technologies subject to full balancing responsibili-ties?

Yes, in principle everyone should have full balancing responsibilities X No, we still need exemptions

Box: Please specify: If exemptions remain necessary, please specify if and in which case and why exemptions would still remain necessary (e.g. small renewable producers, non-mature technolo-gies)? The German renewable energy industry believes that balancing responsibility is possible and desira-ble in systems where there is a level playing field for renewable energy generation. Exemptions should remain in place until markets can guarantee that that there is no discrimination against re-newable energy producers.


21

21

The time is not yet right to make all generation technologies subject to full balancing responsibilities. There are still many backward-looking balancing markets in various Member States that are based on arrangements that only apply to conventional power generation, along with differences in market maturity and penetration of renewable energy production. Therefore, subjecting renewable energy producers to full balancing responsibility would only lead to more discrimination in some European markets and risk bringing the development of renewable energy to a halt. Renewable energy technologies currently provide ancillary services and their participation in balanc-ing markets is already being considered and implemented in Germany. The European Commission should take the initial step to encourage Member States to create functioning intraday and balancing markets that allow for the participation of renewables and flexibility options based on best practice examples.

20. Please assess the importance of stronger EU rules in the following areas to remove grid regulation and infrastructure barriers for renewable electricity deployment:



No opinion

Treatment of curtailment, in-cluding compensation for cur-tailment

X

Transparent and foreseeable grid development, taking into account renewable develop-ment and integrating both TSO and DSO level and smart technologies

X

Predictable transparent and non-discriminatory connection procedure

X

Obligation/priority of connec-tion for renewables X

Cost of grid access, including cost structure X

Legal position of renewable energy developers to chal-lenge grid access decisions by TSOs

X

Transparency on local grid congestion and/or market-based incentives to invest in uncongested areas

X

Box: Comments and other ideas, including whether there are any consideration concerning gas from renewable energy sources, for instance expansion of gas infrastructure, publication of technical rules, please explain. In the last decade, most Member States have had to fight with insufficient grid capacity and long and burdensome processes of grid reinforcement and expansion. This situation negatively affects renew-


22

22

able energy power producers, as the grid is an important factor in propelling renewable energy de-velopment. This is why the use of free grid capacity should be better incentivized, but should not remain the only option. From a socio-economic perspective, grid expansion is, in some areas, the cheaper option. Grid bottlenecks should also be actively managed. As more variable renewable power is fed into the grid, curtailment has increasingly become an issue. Regarding this point, guaranteed or priority access is key to ensuring development of the grid infra-structure that is necessary to effectively integrate renewables in a non-discriminatory way, especially in those Member States whose national legislation does not include priority dispatch provisions. Curtailment should not be understood as a means to optimize grid investments. Non-system security-related curtailment should be voluntary and understood as a service, and thus remunerated accord-ing to clear and transparent rules. Nevertheless, addressing curtailment issues is better carried out at national level. The European Commission could provide guidance to protect renewable energy power producers from discriminatory curtailment and to ensure they are adequately compensated for provid-ing a service. Advancing sector coupling would provide a solution to avoiding curtailment altogether. Until now, the local and district gas heating infrastructure has not been impacted by renewables‘ development. Here, priority access and dispatch for renewable energy should be introduced. The infrastructure could be then used as a means to take in power that would otherwise be curtailed in the area affect-ed by the bottleneck. This power would be exempt from tax and other duties and would be available only to additional loads (which would be selected according to certain prequalification criteria). This option is particularly attractive in areas featuring many historic buildings. As energy retrofitting of these buildings is not possible, they could be connected to the district-heating network and be heated by renewable heating. Regarding the cost of grid access, the transformation of our energy system is a task for society as a whole, and should not be shouldered solely by renewable energy producers. Grid reinforcement and expansion benefit all producers and consumers, therefore their costs should be socialized.

21. Which obstacles, if any, would you see for the dispatching of energy from all genera-tion sources including renewables on the basis of merit order principles? Should there be any exemptions in some specific cases?

X Yes, exemptions are necessary No, merit order is sufficient

Box: Please specify: If yes, in which case and why? What are the lessons from the implementation of RED? BEE believes that maintaining priority dispatch for all renewable energy sources is the only way the European Union can guarantee achievement of the ambitious COP 21 goals agreed upon. Priority dispatch is relevant at a number of different levels:

• For renewable energy sources with significant marginal costs, such as bioenergy, and which come after conventional energy sources in the merit order, (as long as the external costs of conventional energy sources are not fully internalized).


23

23

• For renewable energy sources with low marginal costs, as opposed to conventional energy sources with low marginal costs, (e.g. nuclear power and lignite power plants), for which ex-ternal costs are not internalized or where the insurance premium does not reflect actual risk.

• For renewable energy as opposed to conventional CHP plants that can displace renewable energy power due to revenues from heat sale. Incentives for the use of these plants that in-fluence their place in the merit order intensify the problem.

• In regard to feed-in management, which is not part of the electricity market but is conducted by the transmission system operators. Without priority dispatch for renewable energy sources, the risk that some transmission system operators will favour conventional power plants and thus curtail renewables increases.

Renewable energy should continue to benefit from priority dispatch until a fully transparent, fair and well-functioning power market is in place. This further developed market would include the removal of priority dispatch for conventional power generation and conventional CHP, as well as the existence of functioning and liquid intraday and balancing markets, the full internalization of external costs, the fair use of insurance premiums and the reinforcement and expansion of the grid at both transmission and distribution levels. Curtailment means that renewable power generators will face increasing market risks. Renewable power loss in Germany rose in 2015 by 185% to 1,581 GWh10, representing over 1% of total renewa-ble energy production. This percentage is only expected to rise in the next years, which means the European Commission and Member States need to actively pursue new solutions for them to ad-dress the issue. In order to achieve an economic optimum, the merit order should not only include the real costs of conventional power generation, but also a factor that represents the individual impact generation has on the bottleneck. A solution addressing the problem of surplus power is sector coupling, which makes sense from both an economic and an energy-related point of view. Unfortunately, this alternative has not yet been taken into consideration by many of the Member States, with exception of Denmark, (e.g. power to heat). With an increasing share of fluctuating renewable energy and with solutions to decarbonisation and increased flexibility needed by the energy intensive industry and the transport sector, sector cou-pling can play an important role as part of an overall European strategy. The goal is to use surplus power that cannot, (bottleneck management), or should, (shaving of gen-eration peaks – Spitzenkappung), be taken up by the grid in other sectors. Sector coupling can be gradually driven forward by cost-neutral incentives and can lead to the development of competitive markets and industries providing both power-to-X solutions and innovative ancillary services. It is also best to avoid re-dispatch through active bottleneck management. The transmission system operators should make use of the possibility to predict bottlenecks at an early stage, activate addi-tional loads or shift loads in order to reduce re-dispatch measures.

22. Please assess the importance of stronger EU rules in the following areas to remove administrative barriers to renewable energy deployment:

10 Bundesnetzagentur, “Energy Monitoring Report 2015 published by the Bundesnetzagentur and the Bundeskartellamt“, 2015. Available at: http://www.bundesnetzagentur.de/SharedDocs/Pressemitteilungen/EN/2015/151124_Monitoring.html.


24

24

Very im-

portant

Im-porta

nt

Not very im-

portant

Not im-

portant

No opinion

Creation of a one stop shop at national level to allow for more streamlined permitting procedures X

Online application for permits X A defined maximum time-limit for permitting proce-dures, and effective consequences if deadline is missed

X

Harmonisation of national permitting procedures X Special rules for facilitating small-scale project permit-ting, including simple notification X

Pre-identified geographical areas for renewable ener-gy projects or other measures to integrate renewable energy in spatial and environmental planning

X

Box: Any other views or ideas? To what extent has the RED been successful in reducing unneces-sary administrative barriers for renewable energy projects in the Member States? Please specify. Fair and shorter permit issuing and connection procedures would significantly reduce project devel-opment costs – In this respect, the RED has not helped reduce duration of these procedures. Another important issue is the large number of bodies involved in issuing permits: The European Commission should encourage Member States to streamline procedures and monitor their progress. As regards spatial planning, additional measures could be encouraging Member States to pre-identify geographical areas for renewable projects development, as long as it is not used to hamper deploy-ment in certain areas. The European Commission could also play an important role in removing barriers for small-scale projects, for example by encouraging Member States to allow any of those below a certain size threshold to connect to the grid without undergoing a permit issuing procedure. This could be de-clared as best practice, and would play an important role in accelerating development of small-scale PV, for example.

23. Please identify precise challenges with regard to grid regulation and infrastructure barriers in EU Member States that you are aware of.

In some Member States, difficulties regarding grid regulation faced by small project developers re-viewing the reasons for the long duration until being granted or, in some cases, being refused grid connection remain a significant problem. In Germany, the Clearingstelle EEG can act as a mediator, a clearing panel that deals with disputes regarding the Renewable Energy Sources Act. Other Mem-ber States’ introduction of similar institutions might be a solution to improve grid regulation. Germany also offers additional flexibility in the balancing group for transporting biomethane via the natural gas grid. However, this benefit is only granted for biomethane produced in Germany. Addi-tional flexibility in balancing groups should be granted to all Member States and also for the cross-border transport of biomethane, in order to stimulate a single market.


25

25

Another problem is that interconnections are managed only according to the economic interests of the transmission system operators, leading to a lack of grid efficiency. From a long-term perspective, we also suggest the introduction of DC transmission systems at both high and medium-voltage levels. This would reduce transmission losses and increase grid capacity. For more information on barriers regarding the integration of renewables into the grid, please also consult the PV GRID and RES LEGAL Europe projects11.

24. How would you rate the administrative burden and cost of compliance with the RED for national, regional and local authorities?



No opinion

Administrative burden X Cost of compliance X Box: Please explain. How could the administrative burden and cost of compliance be reduced in the period after 2020?

25. Please rate the importance of stronger EU rules in the following areas to remove bar-riers relating to renewable energy training and certification:



No opinion

Incentives for installers to partic-ipate in certification/qualification schemes

X

Increased control and quality assurance from public authori-ties

X

Understanding of the benefits and potential of renewable tech-nologies by installers

X

Mutual recognition of certificates between different Member States

X

Box: Comments, other ideas, please explain. To what extent has the RED been successful in reduc-ing unnecessary training and certification barriers in the Member States? Strengthening vocational and further training of installers in terms of renewables is a long-term task at both European and national levels. Creating content around the key issues regarding renewable energy and incentivizing the installers to understand the benefits and potential of renewable technol-

11 PV GRID. Available at: http://www.pvgrid.eu/home.html; RES LEGAL Europe. Available at: http://www.res-legal.eu.


26

26

ogies will not only lead to increased quality of workmanship, but also an increased interest in the topic.

26. How can public acceptance towards renewable energy projects and related grid de-velopment be improved?

Social acceptance in Germany is very high, with 93% of respondents favouring further development of renewable energy12. However, local communities sometimes perceive renewable energy projects and grid infrastructure as intrusive and of limited value to the community. It is thus important that public administrations and project developers increase open dialogue and raise awareness. It is also important to increase community participation in projects. As regards public participation, a lean planning process and well-defined roles for the planning bod-ies is crucial. National planning and permit issuing strategies are essential to increase the level of public participation and available information. The active participation of citizens through cooperatives has been identified as a major factor in im-proving the social acceptance of renewable energy projects. Enabling local community ownership that is not greatly complex has become an important issue. In Germany, one of the main deterrents of renewable energy projects at local level is the introduction of mandatory auctioning, beginning in 2017. This system poses new barriers to energy cooperatives’ project development, especially in the area of wind energy. By refusing to make full use of the so-called de minimis rule in the European Commission’s Guidelines on State aid for environmental protection and energy 2014-2020, the Ger-man administration is, de facto, hindering the development of further cooperatives and thus endan-gering social acceptance. With an increased deployment of renewable energy and grid infrastructure, the debate is focused on whether local communities should receive benefits from the projects they host, and how. Benefit sharing aims to facilitate an increased acceptance by local communities by means of direct and/or indirect participation. In particular it is financing that provides an effective strategy to alleviate public opposition.

28. To what extent has the RED been successful in addressing the following EU transport policy objectives?

Very suc-cess-

ful

Suc-cessful

Not very suc-cess-

ful

Not suc-cess-

ful

No opinion

Contribute towards the EU's decarbonisation ob-jectives X

Reduce dependency on oil imports X Increase diversification of transport fuels X Increase energy recovery from wastes X Reduce air pollution, particularly in urban areas X

12 AEE http://www.unendlich-viel-energie.de/die-deutsche-bevoelkerung-will-mehr-erneuerbare-energien


27

27

Strengthen the EU industry and economy competi-tiveness X

Stimulate development and growth of innovative technologies X

Reduce production costs of renewable fuels by lowering the level of investment risk X

Facilitate fuel cost reduction by integration of the EU market for renewable fuels X

By introducing a sectoral goal of 10% renewable energy in the transport sector, the RED set a vital and successful signal for developing alternative fuels and drives. However, the prolonged debate about the advantages and disadvantages of fossil fuel alternatives – especially concerning biofuels originating from food-based crops – has led to legal uncertainties, hereby lowering investment securi-ty in the sector. The revision of the RED to restrict renewable first generation biofuels to a share of only 7%, as well as the introduction of multiple counting, has, de facto, lowered the 10% target. The once ambitious target has been weakened, as multiple counting does not really meet EU policy ob-jectives, but rather only multiplies the contribution of renewables without actually increasing their production and profiting from the benefits (reducing fossil fuel dependency, reducing air pollution). The European biofuel industry is thus struggling, as they cannot make full use of the production ca-pacities that were installed on the basis of trust in European framework conditions. As regards other solutions to sustainable mobility, the RED has not been a strong enough trigger for their development, nor have Member States made use of the available provisions. Electric mobility, hydrogen cars, power to gas or power to liquid are all alternatives for the transport sector which the RED has, until now, not successfully incentivized.

29. Please name the most important barriers hampering the development of sustainable renewable fuels and renewable electricity use in transport?

Please explain, and quantify your replies to the extent possible. In recent years, an emotional discussion about food crops used for biofuels has led to a debate about indirect land use change that has significantly hampered the development of sustainable biofuels. Nevertheless, applying ILUC factors to biofuels only makes sense if these factors are also applied to all industries (including the agriculture, chemical and fossil fuel industries) and to all products (food, feed, raw chemical products and fossil fuels). The fact that these factors are exclusively applied to renewable biofuels only fosters discrimination and leads to major disadvantages for the industry, as this only works in favour of the status quo and conventional fuels. In this context, it is necessary to create long-term framework conditions that guarantee legal certainty and security of investment. BEE believes that there should be a more ambitious aim to increase the share of sustainable renewable fuels in transport. Measures incentivizing increased efficiency in the transport sector, to avoid traffic and to reach a modal shift should be introduced. Existing potential for biomass should be fully exploited and electric mobility, as well as other forms of energy use including hydrogen cars, should be promoted. In terms of biomethane, the problem is that there is no EU-wide biomethane mass-balancing system. This renders the EU-wide trading of biomethane impossible. Creating an integrated European mass-balancing network would enable the removal of this significant barrier.


28

28

As long as the external costs of using fossil energy are not included in the price, electric mobility and other alternatives will remain more costly. Incentives should thus be introduced to promote its use, such as tax incentives, financial support for customers or the quick installation of area-wide charging systems.

Regarding the latter point, the lack of infrastructure poses a massive challenge to the development of renewable mobility and electric mobility, as does the limited range of electric vehicles. Vehicle manu-facturers will only start investing in sustainable mobility once the problem of the infrastructure is ad-dressed. A less significant issue is the continuously higher acquisition costs of electric vehicles. Nevertheless, these initial high costs are balanced out by lower operational costs (for fuel, use and wear) over the vehicle’s lifespan. The European Commission needs to seriously address the topic of sustainable transport. This in-cludes rethinking new cars’ emission levels beyond 2020 (emission levels of 95 g CO2/km should be sought after). Furthermore, standardized driving cycles should be introduced, in order to enable a comparison of emission levels in different Member States. Sector coupling should also play an important role in the transport sector. The value of existing sur-plus electricity to the transport sector is not currently self-evident. Using this potential should be in-centivized.

30. Please rate the most effective means of promoting the consumption of sustainable renewable fuels in the EU transport sector and increasing the uptake of electric vehi-cles:

Very effecfec-tive

Effective Not very effective

Not effec-tive

No opinion

Increased use of certain mar-ket players' obligations at Member State level

X

More harmonised promotion measures at Member States level

X

The introduction of certain market players' obligations at the EU level

X

Targeted financial support for deployment of innovative low-carbon technologies (in par-ticular to the heavy duty transport and aviation indus-try)

X

Increased access to energy system services (such as balancing and voltage and frequency support when using

X


29

29

electric vehicles) Increased access to alterna-tive fuel infrastructure (such as electric vehicle charging points)

X

As part of a reliable and stable framework, binding and ambitious sectoral goals are necessary for an effective transformation our energy system. They are paramount for ensuring investment certainty, and are especially important in the transport sector, where a target of 10% should continue to be included in the RED. Without these sectoral targets, policy will continue to focus on the power sector, leaving the heating and cooling, and especially the transport sector, behind. Fossil fuels remain very cheap, as their price doesn’t include external costs, making it difficult for clean alternatives, such as sustainable renewable fuels and electric mobility, to compete. In the long run, these alternatives will remain more costly, which is why they require binding sectoral goals and increased efforts to decar-bonise transport. The sectoral goals, as well as increasing transport efficiency, should also be ac-companied by research and development initiatives and financing, along with positive incentives geared at changing consumer behaviour.


30

30

German Renewable Energy Federation Bundesverband Erneuerbare Energie e.V. (BEE)

Invalidenstraße 91 10115 Berlin Germany

Tel: +49 30 275 81 70 0 Fax: +49 30 275 81 70 20

www.bee-ev.de

a strong renewable energy directive for 2030 a bee ... · furthermore, the possibility to use new,...

Documents