Draft RES Directive: some sticking points Jaap Jansen
The Commission deserves a lot of credits Promotion of a well-functioning single E market Promotion of a sustainable environment (EU ETS, etc.) Preparing last 23 January’s package >> Yet … the EU policy framework for RES promotion is a rather tedious subject
Draft RES Dir: three sticking points The choice of a new energy numéraire Ensuring reliable accounting and sustainability Guarantees of Origin (GoO)
New numéraire: final energy consumption Relative weights of apples and oranges The use of renewable substitutes in industrial feedstock neglected
Renewables: proper accountancy and sustainability Renewables a 100+ billion €/y business in the EU Renewable feature good for tens of billion €/y !!! Guarantees of Origin (GoO) to cover total quantity of final renewables consumption completely Ensuring reliable accounting of RES Ensuring sustainability of RES supply chain GoO for (imported) biofuels to be urgently considered
Draft RES Dir.: Environmental protection perspective What is a GoO? RES-E Directive 2001/77/EC E-M Directive 2003/54/EC To promote trade in RES-E To reliably verify info for transparency of the consumer’s choice Draft RES Dir.: Environmental protection perspective Tool for national support schemes Tool for state trade for “smooth” target accounting Internal market perspective
Proposed GoO regulation: some issues Redemption after one single use OK !!! Yet flexibility mechanism efficient and transparent??? Intervention bias pro new installations Treaty compatible??? Are consumer concerns addressed at all??? Lock-in at first cash-in of support benefits ??? Compliance sanction??? >> Rigorous redrafting needed
Just a few suggested amendments (I) A GoO is a unique (or at least leading) proof of origin attributes it specifies of the underlying specific quantity of energy: e.g. (Renewable) energy source Production location Production (or issuing) date Sustainability OK (whole supply chain) Date installation entered on line GoO regulation in realm of internal market rules for all uses but one
Some suggested amendments (II) Exception use: application for benefits of a national support scheme Regulation on national support schemes ring-fenced under Env. Protection State Aid rules NO automatic right to use an imported GoO for benefits of a national support scheme Only yes for GoO origin/schemes within joint support scheme bubble Prior fiat Commission needed to start bubble
Thank you j.jansen@ecn.nl