FEDARENE Position Paper – Proposal for the Renewable energy sources Directive

This position paper is based on consultation with the members of FEDARENE, the European Federation of Agencies and Regions for Energy and the Environment, and is in response to the proposal for the Renewable energy sources Directive, released on November 30th 2017.

FEDARENE Position Paper – Proposal for the Renewable energy sources Directive

This position paper is based on consultation with the members of FEDARENE, and is in response to the proposal for the Renewable energy sources Directive. This Position Paper has been draft with the strong support of Riccardo Gonzalez from EREN Castilla y Léon.

Summary of recommendations

  • Main Objectives
    • To extend the main Directive goal from 27 to 30% RES participation over gross final consumption as a binding target
    • Obligate each MS to establish their own national objectives (detailed in electrical, thermal and transport by RES)
  • Funds allocation
    • Diversify public support not only in investment but also in communication, Research, Demonstration & Innovation and business
    • Give the possibility to allocate part of the EU funds dedicated to RES support in successful geographical areas as an incentive to MS and regions or to reserve some specific funds for communication as a percentage (0,1%) of energy
  • Electricity from
    • Defense from accusations related to electricity from RES support schemes with a more equable position as economic distortion; non attending economic signals or obeying basic market rules; etc., putting in context some affirmations, wide the sources of financing, not only by market
    • To maintain the same grid accessibility, priority access and dispatching of
    • Certain flexibility should be allowed to MS related to future changes of support
  • Renewable energy
    • Allow local and regional bodies to be partners, developing the roles of the participants differentiate between energy consumers, suppliers or others as
    • Suggested to downsize to 2 MW and voting rights according to the energy participation
  • Heating and
    • It’s suggested enhances in the “implementing entities” activities as to report the facilities characteristics.
    • It would be necessary an article 23 relevant revision, with an specific development of public actions that include new measurements (to act at local, regional and national level, make “bankables” projects, work with stakeholders, encourage confidence consumer – installer, etc.) many of them also presented in “EU Strategy on Heating and Cooling”
    • it would be need a more neutral treatment about district Nevertheless DH is an opportunity tool for local authorities.
  • Business and technological development and innovation
  • Propose an new article about business and technological development and innovation that works to consolidate current European leadership, defining priority lines or fixing a percentage of the funds to these matters
  • Biomass environmental considerations
    • A meticulous analysis / control of the biomass as energy raw material for energy uses is observed, which provokes a restricted series of requirements / obligations with unequal results at the territorial level.
    • In order to minimize such a situation, a combination of the following solutions could be made:
      • To flexibilize the requirements of fulfillment in different dates and MS according their development.
      • To allocate a bigger amount of E. U. funds to support those MS with less development,
      • Extend the fulfillment of these requirements to any use of these raw
      • Maintain the production of conventional biofuels making a transition with
    • Statistics
      • Stating limits to statistical transfers to 15% to encourage MS to develop theirown RES markets
      • Consider passive energy solar systems as renewable one
      • include “market information” in the national reports
      • Disincentive any kind of labor, economical, etc, dumping in transferences from non-EUcountries.
    • Administrative procedures
      • To state reliable (and none discouraging for consumers) public records of RES
      • Administrative charges not only would be transparent and cost-related but also would be bureaucratically “friendly”.
  • Clarify the responsibility of public administrations in the duration of the whole administrative procedure
  • Introduce a fixed administrative period for “small projects”, extending their size from 50 kW to 100 kW
  • To extent analysis more far than only economic or investment
    • Expand the concepts analyzed more far than investments or capital costs items
    • Act with the principle “first minimize energy consumed and then maximize RES contribution…. after a wider cost – benefit analysis”
  • Regional and local entities relevance
    • Clarify the administrative level competence of each support scheme, giving more relevance to regional and local entities in the management / supporting of renewable
  • Avoid consolidation of fossil fuel consumption
    • Eliminating any kind of concepts that direct or indirectly involve a support or a consolidation of fossil fuels consumption (e. through a positive presence of high efficiency cogeneration)
  • Miscellaneous
    • Introduce the concept of energy urbanism as an item to be necessarily to have intoaccount
    • To extend the type of self-consumer to industry or tertiary sector

Read the full version of the Position Paper